Text

– Amendment 231 to Adopt TSTF-505, TSTF-439, TSTF-591
	ML25086A180
Person / Time
Site:	Fermi
Issue date:	05/02/2025
From:	Shilpa Arora; Plant Licensing Branch III
To:	Peter Dietrich; DTE Electric Company
	Arora S
References
	EPID L 2024-LLA-0034 TSTF-505, TSTF-439, TSTF-591
	Download: ML25086A180 (1)
	v • d • e

May 2, 2025 Peter Dietrich Senior Vice President and Chief Nuclear Officer DTE Electric Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

FERMI UNIT 2 - ISSUANCE OF AMENDMENT NO. 231 RE: ADOPTION OF TSTF-505, PROVIDE RISK-INFORMED EXTENDED COMPLETION TIMES -

RITSTF INITIATIVE 4B, TSTF-439, ELIMINATE SECOND COMPLETION TIMES LIMITING TIME FROM DISCOVERY OF FAILURE TO MEET AN LCO, AND TSTF-591, REVISE THE RISK-INFORMED COMPLETION TIME (RICT)

PROGRAM (EPID L-2024-LLA-0034)

Dear Peter Dietrich:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 231 to Renewed Facility Operating License No. NPF-43, for Fermi, Unit 2 (Fermi 2). This amendment is in response to your application dated March 21, 2024, as supplemented by letters dated December 19, 2024, February 4, 2025, and March 19, 2025.

The amendment adopts Technical Specifications Task Force (TSTF) Travelers TSTF-505, Revision 2, Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b, TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of failure to Meet an LCO, and TSTF-591, Revision 0, Revise the Risk-Informed Completion Time (RICT) Program.

The NRCs related safety evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Surinder S. Arora, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosures:

1. Amendment No. 231 to NPF-43

2. Safety Evaluation cc: Listserv

DTE ELECTRIC COMPANY DOCKET NO. 50-341 FERMI 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 231 Renewed License No. NPF-43

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by DTE Electric Company dated March 21, 2024, as supplemented by letters dated December 19, 2024, February 4, 2025, and March 19, 2025, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-43 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 231, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed license. DTE Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 180 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Ilka Berrios, Acting Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: May 2, 2025 ILKA BERRIOS Digitally signed by ILKA BERRIOS Date: 2025.05.02 08:14:04 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 231 FERMI 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE DOCKET NO. 50-341 Renewed Facility Operating License No. NPF-43 Replace the following page of the Renewed Facility Operating Licenses No. NPF-43 with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.

INSERT REMOVE Technical Specifications Replace the following pages of the Appendix A, Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 1.3-2 1.3-2 1.3-6 1.3-6 1.3-7 1.3-7 1.3-13 1.3-13 1.3-14 3.1-20 3.1-20 3.3-1 3.3-1 3.3-2 3.3-2 3.3.2a 3.3-3 3.3-3 3.3-22 3.3-22 3.3-31 3.3-31 3.3-32 3.3-32 3.3-35 3.3-35 3.3-36 3.3-36 3.3-37 3.3-37 3.3-38 3.3-38 3.3-39 3.3-39 3.3-39a 3.3-46 3.3-46 3.3-47 3.3-47 3.3-50 3.3-50 3.3-50a 3.3-70a 3.3-70a 3.3-70b 3.3-70b 3.3-70d 3.3-70d 3.3-70e 3.3-70e 3.3-71 3.3-71 3.5-1 3.5-1 3.5-2 3.5-2 3.5-2a 3.5-3 3.5-3 3.5-3a 3.5-3a 3.5-12 3.5-12 3.6-5 3.6-5 3.6-6 3.6-6 3.6-7 3.6-7 3.6-8 3.6-8 3.6-9 3.6-9 3.6-10 3.6-10 3.6-12 3.6-12 3.6-22 3.6-22 3.6-23 3.6-23 3.6-25 3.6-25 3.6-33 3.6-33 3.6-35 3.6-35 3.7-1 3.7-1 3.7-1a 3.7-3 3.7-3 3.7-16 3.7-16 3.8-2 3.8-2 3.8-2a 3.8-2a 3.8-2b 3.8-2b 3.8-2c 3.8-2c 3.8-16 3.8-16 3.8-26 3.8-26 3.8-27 3.8-27 5.0-19b 5.0-19b 5.0-19c 5.0-22 5.0-22 5.0-22a Renewed License No. NPF-43 Amendment No. 231 (2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 231, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed license. DTE Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3)

Antitrust Conditions DTE Electric Company shall abide by the agreements and interpretations between it and the Department of Justice relating to Article I, paragraph 3 of the Electric Power Pool Agreement between DTE Electric Company and Consumers Power Company as specified in a letter from the Detroit Edison Company to the Director of Regulation, dated August 13, 1971, and the letter from Richard W. McLaren, Assistant Attorney General, Antitrust Division, U.S. Department of Justice, to Bertram H. Schur, Associate General Counsel, Atomic Energy Commission, dated August 16, 1971.

(4)

Deleted (5)

Deleted (6)

Deleted (7)

Deleted (8)

Deleted (9)

Modifications for Fire Protection (Section 9.5.1, SSER #5 and SSER #6)*

DTE Electric Company shall implement and maintain in effect all provisions of the approved fire protection program as described in its Final Safety Analysis Report for the facility through Amendment 60 and as approved in the SER through Supplement No. 5, subject to the following provision:

(a)

DTE Electric Company may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report (SER) and/or its supplements wherein the license condition is discussed.

Completion Times 1.3 1.3 Completion Times DESCRIPTION (continued)

FERMI - UNIT 2 However, when a subsequent division, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended.

To apply this Completion Time extension, two criteria must first be met.

The subsequent inoperability:

a.

Must exist concurrent with the first inoperability; and

b.

Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a.

The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or

b.

The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each division, subsystem, component or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e.,

"once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery... "

1.3-2 (continued)

Amendment No. lJ4, 231

1.3 Completion Times EXAMPLES (continued)

FERMI - UNIT 2 EXAMPLE 1.3-3 ACTIONS CONDITION A. One Function X subsystem inoperable.

B. One Function Y subsystem inoperable.

C. One Function X subsystem inoperable.

AND One Function Y subsystem inoperable.

REQUIRED ACTION A.1 Restore Function X subsystem to OPERABLE status.

B.1 Restore Function Y subsystem to OPERABLE status.

C.1 Restore Function X subsystem to OPERABLE status.

OR C.2 Restore Function Y subsystem to OPERABLE status.

Completion Times 1.3 COMPLETION TIME 7 days 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (continued) 1.3-6 Amendment No. lJ4, 231

Completion Times 1.3 1.3 Completion Times EXAMPLES FERMI - UNIT 2 EXAMPLE 1.3-3 (continued)

When one Function X subsystem and one Function Y subsystem are inoperable, Condition A and Condition Bare concurrently applicable. The Completion Times for Condition A and Condition Bare tracked separately for each subsystem, starting from the time each subsystem was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second subsystem was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions Band Care exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A.

The remaining Completion Time in Condition A is measured from the time the affected subsystem was declared inoperable (i.e., initial entry into Condition A).

It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCD. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCD. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

(continued) 1.3-7 Amendment No. lJ4, 231

Completion Times 1.3 1.3 Completion Times EXAMPLES FERMI - UNIT 2 EXAMPLE 1.3-7 (continued) is met after Condition Bis entered, Condition Bis exited and operation may continue in accordance with Condition A, provided the Completion Time for Required Action A.2 has not expired.

EXAMPLE 1.3-8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Restore subsystem 7 days subsystem to OPERABLE inoperable.

status.

OR In accordance with the Risk Informed Completion Time Program B. Required B.1 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Action and associated AND Completion Time not B.2 Be in MODE 4.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months met.

When a subsystem is declared inoperable, Condition A is entered. The 7 day Completion Time may be applied as discussed in Example 1.3-2. However, the licensee may elect to apply the Risk Informed Completion Time Program which permits calculation of a Risk Informed Completion Time (RICT) that may be used to complete the Required Action beyond the 7 day Completion Time. The RICT cannot exceed 30 days. After the 7 day Completion Time has expired, the subsystem must be restored to OPERABLE status within the RICT or Condition B must also be entered.

(continued)

1. 3-13 Amendment No. M4-. 231

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-8 (continued)

The Risk Informed Completion Time Program requires recalculation of the RICT to reflect changing plant conditions. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e. not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

If the 7 day Completion Time clock of Condition A has expired and subsequent changes in plant condition result in exiting the applicability of the Risk Informed Completion Time Program without restoring the inoperable subsystem to OPERABLE status, Condition Bis also entered and the Completion Time clocks for Required Actions B.1 and B.2 start.

If the RICT expires or is recalculated to be less than the elapsed time since the Condition was entered and the inoperable subsystem has not been restored to OPERABLE status, Condition Bis also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the inoperable subsystems are restored to OPERABLE status after Condition Bis entered, Condition A is exited, and therefore, the Required Actions of Condition B may be terminated.

IMMEDIATE When "Immediately" is used as a Completion Time, the COMPLETION TIME Required Action should be pursued without delay and in a controlled manner.

FERMI - UNIT 2 1.3-14 Amendment No. 231

3.1 REACTIVITY CONTROL SYSTEMS 3.1.7 Standby Liquid Control (SLC) System LCO 3.1.7 Two SLC subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION A.

One SLC subsystem A.1 Restore SLC subsystem inoperable.

to OPERABLE status.

B.

Two SLC subsystems 8.1 Restore one SLC inoperable.

subsystem to OPERABLE status.

C.

Required Action and C.1 Be in MODE 3.

associated Completion Time not met.

SLC System 3.1. 7 COMPLETION TIME 7 days OR In accordance with the Risk Informed Completion Time Program 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 12 hours FERMI - UNIT 2 3.1-20 Amendment No. 134-,- 231

3.3 INSTRUMENTATION 3.3.1.1 Reactor Protection System (RPS) Instrumentation RPS Instrumentation 3.3.1.1 LCO 3.3.1.1 The RPS instrumentation for each Function in Table 3.3.1.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.1.1-1.

ACTIONS

NOTE -------------------------------------

Separate Condition entry is allowed for each channel.

CONDITION A.

One or more required channels inoperable.

FERMI - UNIT 2 A.1 OR REQUIRED ACTION Place channel in trip.

COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program (continued) 3.3-1 Amendment No. 1J4, lJ9-, 231

ACTIONS CONDITION A.

(continued)

A.2 B.

NOTE ---------

8.1 Not applicable for Functions 2.a, 2.b, 2.c, 2.d, and 2.f.

OR One or more Functions with one or more required channels inoperable in both trip systems.

FERMI - UNIT 2 REQUIRED ACTION

NOTE --------

Not applicable for Functions 2.a, 2.b, 2.c, 2.d, and 2.f.

Place associated trip system in trip.

Place channel in one trip system in trip.

RPS Instrumentation 3.3.1.1 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program (continued) 3.3-2 Amendment No.134, !J9., l-9e-,- 231

ACTIONS B.

(continued)

B.2 Place one trip system in trip.

C.

One or more Functions C.1 Restore RPS trip with RPS trip capability.

capability not maintained.

FERMI - UNIT 2 3.3-2a RPS Instrumentation 3.3.1.1 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (continued)

Amendment No. 231

ACTIONS (continued)

CONDITION D.

Required Action and D.1 associated Completion Time of Condition A, B, or C not met.

E.

As required by E.1 Required Action D.1 and referenced in Table 3.3.1.1-1.

F.

As required by F.1 Required Action D.1 and referenced in Table 3.3.1.1-1.

G.

As required by G.1 Required Action D.1 and referenced in Table 3.3.1.1-1.

H.

Deleted I.

As required by 1.1 Required Action D.1 and referenced in Table 3.3.1.1-1.

J.

As required by J.1 Required Action D.1 and referenced in Table 3.3.1.1-1.

FERMI - UNIT 2 REQUIRED ACTION Enter the Condition referenced in Table 3.3.1.1-1 for the channel.

Reduce THERMAL POWER to< 29.5% RTP.

Be in MODE 2.

Be in MODE 3.

Initiate action to fully insert all insertable control rods in core cells containing one or more fuel assemblies.

Initiate alternate method to detect and suppress thermal hydraulic instability osci 11 at i ans.

RPS Instrumentation 3.3.1.1 COMPLETION TIME Immediately 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 6 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued) 3.3-3 Amendment No. +/-J4., +/-3-9-, 14&, 2-12-,

231

Feedwater and Main Turbine High Water Level Trip Instrumentation 3.3.2.2 3.3 INSTRUMENTATION 3.3.2.2 Feedwater and Main Turbine High Water Level Trip Instrumentation LCO 3.3.2.2 Four channels of feedwater and main turbine high water level trip instrumentation shall be OPERABLE.

APPLICABILITY:

THERMAL POWER 25% RTP.

ACTIONS

NOTE -------------------------------------

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more feedwater A.1 Place channel in 7 days and main turbine high trip.

water level trip OR channel(s) inoperable.

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program B.

Feedwater and main B.1 Restore feedwater and 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months turbine high water main turbine high level trip capability water level trip not maintained.

capability.

C.

Required Action and C.1 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to< 25% RTP.

Time not met.

FERMI - UNIT 2 3.3-22 Amendment No. 134-,- 231

3.3 INSTRUMENTATION ATWS-RPT Instrumentation 3.3.4.1 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation LCO 3.3.4.1 Two channels per trip system for each ATWS-RPT instrumentation Function listed below shall be OPERABLE:

a.

Reactor Vessel Water Level-Low Low, Level 2; and

b.

Reactor Vessel Pressure-High.

APPLICABILITY:

MODE 1.

ACTIONS

NOTE -------------------------------------

Separate Condition entry is allowed for each channel.

CONDITION A.

One or more channels inoperable.

FERMI - UNIT 2 A.1 OR REQUIRED ACTION Restore channel to OPERABLE status.

3.3-31 COMPLETION TIME 14 days OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program (continued)

Amendment No. 134, 231

ACTIONS CONDITION A.

(continued)

A.2 B.

One Function with 8.1 ATWS-RPT trip capability not maintained.

C.

Both Functions with C.1 ATWS-RPT trip capability not maintained.

D.

Required Action and D.1 associated Completion Time not met.

OR D.2 FERMI - UNIT 2 ATWS-RPT Instrumentation 3.3.4.1 REQUIRED ACTION COMPLETION TIME

NOTE ---------

Not applicable if inoperable channel is the result of an inoperable breaker.

Place channel in 14 days trip.

OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program Restore ATWS-RPT trip 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months capability.

Restore ATWS-RPT trip 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months capability for one Function.

Remove the associated 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months recirculation pump from service.

Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 3.3-32 Amendment No. 134, 231

ACTIONS (continued)

CONDITION

8.

As required by Required Action A.1 and referenced in Tab l e 3. 3. 5. 1-1.

FERMI - UNIT 2 8.1 AND ECCS Instrumentation 3.3.5.1 REQUIRED ACTION

NOTE --------

Only applicable for Functions 1.a, 1.b, 2.a, 2.b, 2.d, and 2.g.

Declare supported feature(s) inoperable when its redundant feature ECCS initiation capability is inoperable.

COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of initiation capability for feature(s) in both divisions 8.2

NOTE--------

AND 8.3 Only applicable for Functions 3.a and 3.b.

Declare High Pressure Coolant Injection (HPCI) System inoperable.

Place channel in trip.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of HPCI initiation capability 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program 3.3-35 (continued)

Amendment No. 1J4, 211,231

ACTIONS (continued)

CONDITION C.

As required by Required Action A.1 and referenced in Table 3.3.5.1-1.

FERMI - UNIT 2 C.1 AND C.2 ECCS Instrumentation 3.3.5.1 REQUIRED ACTION

NOTE --------

Only applicable for Functions 1.c, 2.c, 2.e, and 2.f.

Declare supported feature(s) inoperable when its redundant feature ECCS initiation capability is inoperable.

Restore channel to OPERABLE status.

COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of initiation capability for feature(s) in both divisions 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program (continued) 3.3-36 Amendment No. 1J4, 211,231

ACTIONS (continued)

CONDITION D.

As required by Required Action A.1 and referenced in Tab l e 3. 3. 5. 1-1.

FERMI - UNIT 2 ECCS Instrumentation 3.3.5.1 D.1 AND REQUIRED ACTION

NOTE ---------

Only applicable if HPCI pump suction is not aligned to the suppression pool.

Declare HPCI System inoperable.

D.2.1 Place channel in trip.

OR D.2.2 Align the HPCI pump suction to the suppression pool.

COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of HPCI initiation capability 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued) 3.3-37 Amendment No. 134-,- 231

ACTIONS (continued)

CONDITION E.

As required by Required Action A.1 and referenced in Tab l e 3. 3. 5. 1-1.

FERMI - UNIT 2 E.1 AND E.2 REQUIRED ACTION Declare Automatic Depressurization System (ADS) valves inoperable.

Place channel in trip.

ECCS Instrumentation 3.3.5.1 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of ADS initiation capability in both trip systems 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCI or reactor core isolation cooling (RCIC) inoperable AND (continued) 3.3-38 Amendment No. 134-,- 231

ACTIONS CONDITION E.

(continued)

F.

As required by Required Action A.1 and referenced in Tab l e 3. 3. 5. 1-1.

FERMI - UNIT 2 F.1 AND ECCS Instrumentation 3.3.5.1 REQUIRED ACTION

NOTE --------

Only applicable for Functions 4.c, 4.e, 4.f, 4.g, 5.c, 5.e, 5.f, and 5.g.

Declare ADS valves inoperable.

COMPLETION TIME 8 days OR In accordance with the Risk Informed Completion Time Program 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery of loss of ADS initiation capability in both trip systems (continued) 3.3-39 Amendment No. 134-,- 231

ACTIONS F.

(continued)

F.2 Restore channel to OPERABLE status.

G.

Required Action and G.1 Declare associated associated Completion supported feature(s)

Time of Condition B, inoperable.

C, D, E, or F not met.

FERMI - UNIT 2 3.3-39a ECCS Instrumentation 3.3.5.1 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months or in accordance with the Risk Informed Completion Time Program from discovery of inoperable channel concurrent with HPCI or RCIC inoperable AND 8 days OR In accordance with the Risk Informed Completion Time Program Immediately Amendment No. 231

3.3 INSTRUMENTATION RCIC System Instrumentation 3.3.5.2 3.3.5.2 Reactor Core Isolation Cooling (RCIC) System Instrumentation LCO 3.3.5.2 The RCIC System instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 with reactor steam dome pressure> 150 psig.

ACTIONS

NOTE -------------------------------------

Separate Condition entry is allowed for each channel.

CONDITION A.

One or more channels A.1 inoperable.

B.

As required by B.1 Required Action A.1 and referenced in Table 3. 3. 5. 2-1.

AND B.2 FERMI - UNIT 2 REQUIRED ACTION COMPLETION TIME Enter the Condition Immediately referenced in Table 3.3.5.2-1 for the channel.

Declare RCIC System 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from inoperable.

discovery of loss of RCIC initiation capability Place channel in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months trip.

OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program 3.3-46 (continued)

Amendment No. 134-,- 231

ACTIONS (continued)

CONDITION C.

As required by C.1 Required Action A.1 and referenced in Tab l e 3. 3. 5. 2 -1.

D.

As required by D.1 Required Action A.1 and referenced in Table 3. 3. 5. 2-1.

AND D.2.1 OR D.2.2 E.

Required Action and E.1 associated Completion Time of Condition B, C, or D not met.

FERMI - UNIT 2 RCIC System Instrumentation 3.3.5.2 REQUIRED ACTION COMPLETION TIME Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

NOTE ---------

Only applicable if RCIC pump suction is not aligned to the suppression pool.

Declare RCIC System 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from inoperable.

discovery of loss of RCIC initiation capability Place channel in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months trip.

OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program Align RCIC pump 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months suction to the suppression pool.

Declare RCIC System Immediately inoperable.

3.3-47 Amendment No. 134-,- 231

Primary Containment Isolation Instrumentation 3.3.6.1 3.3 INSTRUMENTATION 3.3.6.1 Primary Containment Isolation Instrumentation LCO 3.3.6.1 The primary containment isolation instrumentation for each Function in Table 3.3.6.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.6.1-1.

ACTIONS

NOTES ------------------------------------

1. Penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each channel.

CONDITION A.

One or more required channels inoperable.

A.1 REQUIRED ACTION Place channel in trip.

COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Functions 2.a, 2.c, 2.d, 6.b, 7.a, and 7.b OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Functions other than Functions 2.a, 2.c, 2.d, 6.b, 7.a, and 7.b (continued)

FERMI - UNIT 2 3.3-50 Amendment No. 1J4, 1-73-, 189-, 2-12-, 231

ACTIONS CONDITION A.

(continued)

NOTE -----------

With a Table 3.3.6.1-1 Function 5.c channel inoperable, isolation capability is considered maintained&ovided Function 5.b is OPE LE in the affected room.

B.

One or more automatic Functions with isolation capability not maintained.

FERMI - UNIT 2 Primary Containment Isolation Instrumentation 3.3.6.1 REQUIRED ACTION COMPLETION TIME OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program B.1 Restore isolation 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months capability.

(continued) 3.3-50a Amendment No. 231

FERMI - UNIT 2 3.3-70a Amendment No. 212, 222, 231 MVP Trip Instrumentation 3.3.7.2 3.3 INSTRUMENTATION 3.3.7.2 Mechanical Vacuum Pump (MVP) Trip Instrumentation LCO 3.3.7.2 Four channels of Main Steam Line Radiation High Function for the MVP trip shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2 with any MVP in service, any main steam line not isolated, and THERMAL POWER 10% RTP.

ACTIONS

NOTE-------------------------------------

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required channels inoperable.

A.1 Restore channel to OPERABLE status.

OR 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program (continued)

FERMI - UNIT 2 3.3-70b Amendment No. 212. 231 MVP Trip Instrumentation 3.3.7.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.2

NOTE--------

Not applicable if inoperable channel is the result of a non-functional MVP breaker.

Place channel in trip.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program B. MVP trip capability not maintained.

B.1 Restore trip capability.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months C. Required Action and associated Completion Time of Condition A or B not met.

C.1 Isolate the associated MVP(s).

OR C.2 Remove the associated MVP breaker(s) from service.

OR C.3 Isolate the main steam lines.

OR C.4 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours

FERMI - UNIT 2 3.3-70d Amendment No. 212, 222, 231 GSE Trip Instrumentation 3.3.7.3 3.3 INSTRUMENTATION 3.3.7.3 Gland Seal Exhauster (GSE) Trip Instrumentation LCO 3.3.7.3 Four channels of Main Steam Line Radiation High Function for the main turbine GSE trip shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2 with any GSE in service, any main steam line not isolated, and THERMAL POWER 10% RTP.

ACTIONS

NOTE-------------------------------------

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required channels inoperable.

A.1 Restore channel to OPERABLE status.

OR 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program (continued)

FERMI - UNIT 2 3.3-70e Amendment No. 212, 231 GSE Trip Instrumentation 3.3.7.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.2

NOTE--------

Not applicable if inoperable channel is the result of a non-functional GSE breaker.

Place channel in trip.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program B. GSE trip capability not maintained.

B.1 Restore trip capability.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months C. Required Action and associated Completion Time of Condition A or B not met.

C.1 Isolate the associated GSE(s).

OR C.2 Remove the associated GSE breaker(s) from service.

OR C.3 Isolate the main steam lines.

OR C.4 Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 12 hours

FERMI - UNIT 2 3.3-71 Amendment No. 134, 223, 231 LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

NOTE-------------------------------------

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more buses with one or more channels inoperable.

A.1 Restore channel to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR

NOTE------

Not applicable when trip capability is not maintained.

In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

OR One or more buses with LOP trip capability not maintained.

B.1 Declare associated EDG inoperable.

Immediately

FERMI - UNIT 2 3.5-1 Amendment No. 134, 163, 211, 231 ECCS Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of five safety/relief valves shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3, except high pressure coolant injection (HPCI) and ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.

ACTIONS

NOTE-------------------------------------

LCO 3.0.4.b is not applicable to HPCI.

CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS injection/spray subsystem inoperable.

A.1 Restore low pressure ECCS injection/spray subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. One LPCI pump in both LPCI subsystems inoperable.

B.1 Restore both LPCI pumps to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program (continued)

FERMI - UNIT 2 3.5-2 Amendment No. 134, 194, 231 ECCS Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One CSS subsystem inoperable.

AND One LPCI subsystem inoperable.

C.1 Restore CSS subsystem to OPERABLE status.

OR C.2 Restore LPCI subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program D. Required Action and associated Completion Time of Condition A, B, or C not met.

D.1

NOTE--------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E. HPCI System inoperable.

E.1 Verify by administrative means RCIC System is OPERABLE.

AND E.2 Restore HPCI System to OPERABLE status.

Immediately 14 days OR In accordance with the Risk Informed Completion Time Program (continued)

FERMI - UNIT 2 3.5-2a Amendment No. 231 ECCS Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. HPCI System inoperable.

AND Condition A, or Condition B, or Condition C entered.

F.1 Restore HPCI System to OPERABLE status.

OR F.2 Restore low pressure ECCS injection/spray subsystem(s) to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program G. One ADS valve inoperable.

G.1 Restore ADS valve to OPERABLE status.

14 days OR In accordance with the Risk Informed Completion Time Program (continued)

FERMI - UNIT 2 3.5-3 Amendment No. 134, 194, 231 ECCS Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. One ADS valve inoperable.

AND Condition A or Condition B entered.

H.1 Restore ADS valve to OPERABLE status.

OR H.2 Restore low pressure ECCS injection/spray subsystem(s) to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program I. Required Action and associated Completion Time of Condition E, F, G, or H not met.

I.1

NOTE--------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

FERMI - UNIT 2 3.5-3a Amendment No. 194, 231 ECCS Operating 3.5.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME J. Two or more ADS valves inoperable.

J.1 Be in MODE 3.

AND J.2 Reduce reactor steam dome pressure to 150 psig.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours K. Two or more low pressure ECCS injection/spray subsystems inoperable for reasons other than Condition B or C.

OR HPCI System and one or more ADS valves inoperable.

OR Condition C and Condition G entered.

K.1 Enter LCO 3.0.3.

Immediately

RCIC System 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.3 RCIC System LCO 3.5.3 The RCIC System shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 with reactor steam dome pressure> 150 psig.

ACTIONS

NOTE -------------------------------------

LCO 3.0.4.b is not applicable to RCIC.

CONDITION REQUIRED ACTION COMPLETION TIME A.

RCIC System A.1 Verify by Immediately inoperable.

administrative means High Pressure Coolant Injection System is OPERABLE.

AND A.2 Restore RCIC System 14 days to OPERABLE status.

OR In accordance with the Risk Informed Completion Time Program B.

Required Action and 8.1

NOTE --------

associated Completion LCO 3.0.4.a is not Time not met.

applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months FERMI - UNIT 2 3.5-12 Amendment No. 1J4, 1-eJ., 194, 2-1-l, 231

FERMI - UNIT 2 3.6-5 Amendment No. 134, 231 Primary Containment Air Lock 3.6.1.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued)

B.2 Lock an OPERABLE door closed.

AND B.3 --------NOTE---------

Air lock doors in high radiation areas or areas with limited access due to inerting may be verified locked closed by administrative means.

Verify an OPERABLE door is locked closed.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Once per 31 days C. Primary containment air lock inoperable for reasons other than Condition A or B.

C.1 Initiate action to evaluate primary containment overall leakage rate per LCO 3.6.1.1, using current air lock test results.

AND C.2 Verify a door is closed.

AND C.3 Restore air lock to OPERABLE status.

Immediately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 24 hours OR

NOTE------

Not applicable if leakage exceeds limits or if loss of function.

(continued)

FERMI - UNIT 2 3.6-6 Amendment No. 134, 201, 231 Primary Containment Air Lock 3.6.1.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued)

In accordance with the Risk Informed Completion Time Program D. Required Action and associated Completion Time not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.1.2.1

NOTES------------------

1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

2. Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.1.

Perform required primary containment air lock leakage rate testing in accordance with the Primary Containment Leakage Rate Testing Program.

In accordance with the Primary Containment Leakage Rate Testing Program SR 3.6.1.2.2 Verify only one door in the primary containment air lock can be opened at a time.

In accordance with the Surveillance Frequency Control Program

FERMI - UNIT 2 3.6-7 Amendment No. 134, 223, 231 PCIVs 3.6.1.3 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)

LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

NOTES------------------------------------

1. Penetration flow paths may be unisolated intermittently under administrative controls.

2. Separate Condition entry is allowed for each penetration flow path.

3. Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.

4. Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment," when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A. ---------NOTE---------

Only applicable to penetration flow paths with two PCIVs.

One or more penetration flow paths with one PCIV inoperable, except due to leakage not within limit.

A.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

AND 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except for main steam line OR In accordance with the Risk Informed Completion Time Program AND 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for main steam line (continued)

FERMI - UNIT 2 3.6-8 Amendment No. 134, 231 PCIVs 3.6.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.2

NOTES--------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected penetration flow path is isolated.

OR In accordance with the Risk Informed Completion Time Program Once per 31 days following isolation for isolation devices outside primary containment AND (continued)

FERMI - UNIT 2 3.6-9 Amendment No. 134, 231 PCIVs 3.6.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

Prior to entering MODE 2 or 3 from MODE 4, if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment B. ---------NOTE---------

Only applicable to penetration flow paths with two PCIVs.

One or more penetration flow paths with two PCIVs inoperable, except due to leakage not within limit.

B.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (continued)

FERMI - UNIT 2 3.6-10 Amendment No. 134, 231 PCIVs 3.6.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. ---------NOTE---------

Only applicable to penetration flow paths with only one PCIV.

One or more penetration flow paths with one PCIV inoperable except due to leakage not within limit.

C.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

AND C.2

NOTES--------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected penetration flow path is isolated.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months except for excess flow check valves (EFCVs) and penetrations with a closed system AND 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for EFCVs and penetrations with a closed system Once per 31 days following isolation (continued)

FERMI - UNIT 2 3.6-12 Amendment No. 134, 231 PCIVs 3.6.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. (continued)

NOTES------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

3. Only applicable to penetration flow paths isolated to restore leakage to within limits.

D.2 Verify the affected penetration flow path is isolated.

Once per 31 days following isolation for isolation devices outside primary containment AND Prior to entering MODE 2 or 3 from MODE 4, if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment (continued)

FERMI - UNIT 2 3.6-22 Amendment No. 134, 231 Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.7 3.6 CONTAINMENT SYSTEMS 3.6.1.7 Reactor Building-to-Suppression Chamber Vacuum Breakers LCO 3.6.1.7 Each reactor building-to-suppression chamber vacuum breaker shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

NOTE-------------------------------------

Separate Condition entry is allowed for each line.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more lines with one reactor building-to-suppression chamber vacuum breaker not closed.

A.1 Close the open vacuum breaker.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. One or more lines with two reactor building-to-suppression chamber vacuum breakers not closed.

B.1 Close one open vacuum breaker.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months C. One line with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening.

C.1 Restore the vacuum breaker(s) to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR

NOTE------

Not applicable when a loss of function occurs.

In accordance with the Risk Informed Completion Time Program (continued)

FERMI - UNIT 2 3.6-23 Amendment No. 134, 194, 231 Reactor Building-to-Suppression Chamber Vacuum Breakers 3.6.1.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and Associated Completion Time of Condition C not met.

D.1

NOTE--------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E. Two lines with one or more reactor building-to-suppression chamber vacuum breakers inoperable for opening.

E.1 Restore all vacuum breakers in one line to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR

NOTE------

Not applicable when a loss of function occurs.

In accordance with the Risk Informed Completion Time Program F. Required Action and Associated Completion Time of Condition A, B, or E not met.

F.1 Be in MODE 3.

AND F.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

FERMI - UNIT 2 3.6-25 Amendment No. 134, 194, 231 Suppression Chamber-to-Drywell Vacuum Breakers 3.6.1.8 3.6 CONTAINMENT SYSTEMS 3.6.1.8 Suppression Chamber-to-Drywell Vacuum Breakers LCO 3.6.1.8 Twelve suppression chamber-to-drywell vacuum breakers shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One suppression chamber-to-drywell vacuum breaker inoperable for opening.

A.1 Restore vacuum breaker to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

B.1 --------NOTE--------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. One or more suppression chamber-to-drywell vacuum breaker not closed.

C.1 Close the open vacuum breaker(s).

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months D. Required Action and associated Completion Time of Condition C not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

FERMI - UNIT 2 3.6-33 Amendment No. 134, 194, 231 RHR Suppression Pool Cooling 3.6.2.3 3.6 CONTAINMENT SYSTEMS 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling LCO 3.6.2.3 Two RHR suppression pool cooling subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression pool cooling subsystem inoperable.

A.1 Restore RHR suppression pool cooling subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

B.1

NOTE--------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months C. Two RHR suppression pool cooling subsystems inoperable.

C.1 Restore one RHR suppression pool cooling subsystem to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months D. Required Action and associated Completion Time of Condition C not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

FERMI - UNIT 2 3.6-35 Amendment No. 134, 194, 231 RHR Suppression Pool Spray 3.6.2.4 3.6 CONTAINMENT SYSTEMS 3.6.2.4 Residual Heat Removal (RHR) Suppression Pool Spray LCO 3.6.2.4 Two RHR suppression pool spray subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR suppression pool spray subsystem inoperable.

A.1 Restore RHR suppression pool spray subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. Two RHR suppression pool spray subsystems inoperable.

B.1 Restore one RHR suppression pool spray subsystem to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months C. Required Action and associated Completion Time not met.

C.1 --------NOTE--------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

FERMI - UNIT 2 3.7-1 Amendment No. 134, 231 RHRSW System 3.7.1 3.7 PLANT SYSTEMS 3.7.1 Residual Heat Removal Service Water (RHRSW) System LCO 3.7.1 Two RHRSW subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHRSW pump inoperable.

A.1 Restore RHRSW pump to OPERABLE status.

30 days B. One RHRSW pump in each subsystem inoperable.

B.1 Restore one RHRSW pump to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program C. One RHRSW subsystem inoperable for reasons other than Condition A.

C.1

NOTE---------

Enter applicable Conditions and Required Actions of LCO 3.4.8, "Residual Heat Removal (RHR)

Shutdown Cooling System Hot Shutdown,"

for RHR shutdown cooling made inoperable by RHRSW System.

(continued)

FERMI - UNIT 2 3.7-1a Amendment No. 231 RHRSW System 3.7.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued)

Restore RHRSW subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program D. Required Action and associated Completion Time of Condition A, B, or C not met.

D.1

NOTE---------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E. Both RHRSW subsystems inoperable for reasons other than Condition B.

E.1

NOTE---------

Enter applicable Conditions and Required Actions of LCO 3.4.8 for RHR shutdown cooling made inoperable by RHRSW System.

Restore one RHRSW subsystem to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months F. Required Action and associated Completion Time of Condition E not met.

F.1 Be in MODE 3.

AND F.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours

FERMI - UNIT 2 3.7-3 Amendment No. 134,209,225,226,231 EECW/EESW System and UHS 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS)

LCO 3.7.2 Two EECW/EESW subsystems and UHS shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

NOTES----------------------------------

1. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources-Operating," for diesel generator made inoperable by UHS.

2. Enter applicable Conditions and Required Actions of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown," for RHR shutdown cooling made inoperable by EECW/EESW or UHS.

CONDITION REQUIRED ACTION COMPLETION TIME A. One reservoir inoperable.

A.1 Restore reservoir to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. One EECW/EESW subsystem inoperable for reasons other than Condition A.

B.1 Restore the EECW/EESW subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program (continued)

FERMI - UNIT 2 3.7-16 Amendment No. 134,231 Main Turbine Bypass System and Moisture Separator Reheater 3.7.6 3.7 PLANT SYSTEMS 3.7.6 The Main Turbine Bypass System and Moisture Separator Reheater LCO 3.7.6 The Main Turbine Bypass System and Moisture Separator Reheater shall be OPERABLE.

OR LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)," limits for an inoperable Main Turbine Bypass System and Moisture Separator Reheater, as specified in the COLR, are made applicable.

APPLICABILITY:

THERMAL POWER 25% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the LCO not met.

A.1 Satisfy the requirements of the LCO.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Reduce THERMAL POWER to < 25% RTP.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

FERMI - UNIT 2 3.8-2 Amendment No. 134, 171, 170, 175, 222, 231 AC Sources Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.4.1 Determine OPERABLE EDG(s) are not inoperable due to common cause failure.

OR A.4.2 Perform SR 3.8.1.2 for OPERABLE EDG(s).

AND A.5 Restore EDG to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from discovery of unavailability of CTG 11-1 AND 14 days OR In accordance with the Risk Informed Completion Time Program B. Both EDGs in one division inoperable.

B.1 Perform SR 3.8.1.1 for OPERABLE offsite circuit(s).

AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter (continued)

FERMI - UNIT 2 3.8-2a Amendment No. 170, 175, 222, 226, 231 AC Sources Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued)

B.2 Declare required feature(s), supported by the inoperable EDGs, inoperable when the redundant required feature(s) are inoperable.

AND B.3.1 Determine OPERABLE EDG(s) are not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 for OPERABLE EDG(s).

AND B.4 Restore one EDG in the division to OPERABLE status.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of the inoperable EDGs concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program C. One or both EDGs in both divisions inoperable.

C.1 Restore both EDGs in one division to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months D. One offsite circuit inoperable.

D.1 Perform SR 3.8.1.1 for OPERABLE offsite circuit.

AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter (continued)

FERMI - UNIT 2 3.8-2b Amendment No. 170, 175, 222, 231 AC Sources Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. (continued)

D.2 Declare required feature(s) with no offsite power available inoperable when the redundant required feature(s) are inoperable.

AND D.3 Restore offsite circuit to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one division concurrent with inoperability of redundant required feature(s) 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program E. Two offsite circuits inoperable.

E.1 Declare required feature(s) inoperable when the redundant required feature(s) are inoperable.

AND E.2 Restore one offsite circuit to OPERABLE status.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of Condition E concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR In accordance with the Risk Informed Completion Time Program (continued)

FERMI - UNIT 2 3.8-2c Amendment No. 175, 194, 231 AC Sources Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. One offsite circuit inoperable.

AND One or both EDGs in one Division inoperable.

NOTE------------

Enter applicable Conditions and Required Actions of LCO 3.8.7, "Distribution Systems - Operating," when Condition F is entered with no AC power source to one or more 4160 V buses 64B, 64C, 65E or 65F.

F.1 Restore offsite circuit to OPERABLE status.

OR F.2 Restore both EDGs in the Division to OPERABLE status.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR In accordance with the Risk Informed Completion Time Program 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR In accordance with the Risk Informed Completion Time Program G. Required Action and Associated Completion Time of Condition A, B, C, D, E or F not met.

G.1

NOTE--------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

FERMI - UNIT 2 3.8-16 Amendment No. 134, 194, 231 DC Sources Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources Operating LCO 3.8.4 The Division I and Division II DC electrical power subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One battery charger inoperable.

A.1 Restore battery charger to OPERABLE status.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months OR In accordance with the Risk Informed Completion Time Program B. One DC electrical power subsystem inoperable for reasons other than Condition A.

B.1 Restore DC electrical power subsystem to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program C. Required Action and Associated Completion Time not met.

C.1

NOTE--------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

FERMI - UNIT 2 3.8-26 Amendment No. 134, 231 Distribution Systems Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Distribution Systems-Operating LCO 3.8.7 The following Division I and Division II AC and DC electrical power distribution subsystems shall be OPERABLE:

a.

AC electrical power distribution subsystems:

Division I Division II

1. 4160 V Buses 11EA, 12EB 13EC, 14ED 64B, 64C 65E, 65F

2. 480 V Buses 72EA, 72EB 72EC, 72ED 72B, 72C 72E, 72F

3. 120 V MPU 1 MPU 2

b.

DC electrical power distribution subsystems:

Division I Division II

1. 130 V Distribution 2PA-2 2PB-2 Cabinet

2. 260 V MCC 2PA-1 2PB-1 APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required AC electrical power distribution subsystems inoperable.

A.1 Restore AC electrical power distribution subsystem(s) to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OR In accordance with the Risk Informed Completion Time Program (continued)

FERMI - UNIT 2 3.8-27 Amendment No. 134 194, 201, 231 Distribution Systems Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required DC electrical power distribution subsystems inoperable.

B.1 Restore DC electrical power distribution subsystem(s) to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program C. Required Action and associated Completion Time of Condition A or B not met.

C.1

NOTE--------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months D. Two or more required electrical power distribution subsystems inoperable that result in a loss of function.

D.1 Enter LCO 3.0.3.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct breaker alignments and voltage to required AC and DC electrical power distribution subsystems.

In accordance with the Surveillance Frequency Control Program

FERMI - UNIT 2 5.0-19b Amendment No. 218, 222, 231 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Surveillance Frequency Control Program (continued)

c.

The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

5.5.16 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, Risk-Managed Technical Specifications (RMTS) Guidelines. The program shall include the following:

a.

The RICT may not exceed 30 days;

b.

A RICT may only be utilized in MODE 1 and 2;

c.

When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on RICT.

1.

For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2.

For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

3.

Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

(continued)

FERMI - UNIT 2 5.0-19c Amendment No. 231 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.16 Risk Informed Completion Time Program (continued)

d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2.

Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the functions(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

e.

A RICT calculation must include the following hazard groups:

internal flood and internal events PRA model, internal fire PRA model, and seismic penalty factor. Changes to these means assessing the hazard groups require prior to NRC approval.

f.

The PRA models used to calculate a RICT shall be maintained and upgraded in accordance with the processes endorsed in the regulatory positions of Regulatory Guide 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities.

g.

A report shall be submitted in accordance with Specification 5.6.9 before a newly developed method is used to calculate a RICT.

FERMI - UNIT 2 5.0-22 Amendment No. 134, 159, 195. 231 Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.6 Safety Relief Valve Challenge Report The main steam line Safety Relief Valve (SRV) Report documenting all challenges to SRVs during the previous calendar year shall be submitted by April 30 of each year.

5.6.7 PAM Report When a report is required by condition B or F of LCO 3.3.3.1, Post Accident Monitoring (PAM) Instrumentation, a report shall be submitted within the following 14 days. The report shall outline the action taken, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.8 Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR)

a.

RCS pressure and temperature limits for heatup, cooldown, low temperature operation, criticality, and inservice leakage and hydrostatic testing as well as heatup and cooldown rates shall be established and documented in the PTLR for the following:

1.

Limiting Condition for Operation Section 3.4.10, RCS Pressure and Temperature (P/T) Limits.

2.

Surveillance Requirement Section 3.4.10, RCS Pressure and Temperature (P/T) Limits.

b.

The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in the following document:

1.

NEDC-33178P-A, GE Hitachi Nuclear Energy Methodology for Development of Reactor Pressure Vessel Pressure-Temperature Curves, Revision 1, June 2009.

c.

The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto.

(continued)

FERMI - UNIT 2 5.0-22a Amendment No. 231 Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.9 Risk Informed Completion Time (RICT) Program Upgrade Report A report describing newly developed methods and their implementation must be submitted following a probabilistic risk assessment (PRA) upgrade associated with newly developed methods and prior to the first use of those methods to calculate a RICT.

The report shall include:

a.

The PRA models upgraded to include newly developed methods;

b.

A description of the acceptability of the newly developed methods consistent with Section 5.2 of PWROG-19027-NP, Revision 2, Newly Developed Method Requirements and Peer Review;

c.

Any open findings from the peer-review of the implementation of the newly developed methods and how those findings were dispositioned; and

d.

All changes to key assumptions related to newly developed methods or their implementation.

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 231 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-43 DTE ELECTRIC COMPANY FERMI-2 DOCKET NO. 50-341 REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-505, REVISION 2, TSTF-439, REVISION 2, AND TSTF-591, REVISION 0

1.0 INTRODUCTION

By application submitted to the U.S. Nuclear Regulatory Commission (NRC, the Commission) dated March 21, 2024 (Reference 1), as supplemented by letters dated December 19, 2024, February 4, 2025, and March 19, 2025 (References 2, 9, and 48 respectively), DTE Electric Company, (DTE, the licensee) submitted a license amendment request (LAR) to modify the technical specifications (TS) for Fermi, Unit -2 (Fermi 2).

The proposed changes in the LAR are based on three Technical Specifications Task Force (TSTF) Travelers:

TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, dated July 2, 2018 (Reference 3). The amendment would revise TS requirements to permit the use of risk-informed completion times (RICTs) for actions to be taken when limiting conditions for operation (LCOs) are not met. The NRC issued a final model safety evaluation (SE) approving TSTF-505, Revision 2, on November 21, 2018 (Reference 4).

TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO (Reference 11). The amendment would allow the elimination of second completion times that limit the time from discovery of the failure to meet an LCO. The NRC authorized the use of TSTF-439 in a letter dated January 11, 2006 (Reference 29).

TSTF-591, Revision 0, Revise Risk Informed Completion Time (RICT) Program, dated March 22, 2022 (Reference 30). The NRC issued an SE approving TSTF-591 on September 21, 2023 (Reference 31). The amendment would revise the TS Section 5.5 requirements regarding changes to the risk assessment and add a reporting requirement to TS Section 5.6.

The NRC staff participated in a regulatory audit in October 2024 to ascertain the information needed to support its review of the application and to develop requests for additional information, as needed (Reference 5). Following the regulatory audit, the licensee submitted supplemental letters dated December 19, 2024, February 4, 2025, and March 19, 2025, which included additional information resulting from the audit. On February 3, 2025, the NRC staff issued an audit summary (Reference 6).

The licensee has proposed variations from the TS changes described in TSTF-505, Revision 2, which are described in section 2.5 of this SE.

The supplemental letters dated December 19, 2024, February 4, 2025, and March 19, 2025, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration (NSHC) determination as published in the Federal Register (FR) on May 14, 2024 (89 FR 41999).

2.0 REGULATORY EVALUATION

2.1 Regulatory Review 2.1.1 Applicable Regulations Title 10 of the Code of Federal Regulations (10 CFR) Part 50 provides the general provisions for Domestic Licensing of Production and Utilization Facilities. The general provisions include but are not limited to establishing the regulatory requirements that a licensee must adhere to for the submittal of a license application. The NRC staff has identified the following applicable sections within 10 CFR Part 50 for the NRC staffs review of the licensees proposed changes:

10 CFR 50.36, Technical specifications, which specifies the content and information that must be included in the licensees TS. In accordance with 10 CFR 50.36(c), the TSs are required to include (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.

10 CFR 50.55a, Codes and standards, of which 10 CFR 50.55a(h), Protection and safety systems, specifies the requirements for protections systems of the nuclear power reactors of all types.

10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, (i.e., the Maintenance Rule), which requires that the power reactor licensees monitor the performance or condition of structures, systems, and components against licensee-established goals in a manner sufficient to provide reasonable assurance that such structures, systems, and components are capable of fulfilling their intended functions.

2.1.2 Regulatory Guidance NRC Regulatory Guides (RGs) provide one way for licensees to ensure compliance with the NRCs regulations. The NRC staff considered the following guidance, and industry guidance endorsed by the NRC, during its review of the proposed changes:

RG 1.200, Revision 2, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, dated March 2009 (Reference 7) and RG 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities, dated December 2020 (Reference 8).

RG 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, Revision 3, dated January 2018 (Reference 10).

RG 1.177, An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications, Revision 2, dated January 2021 (Reference 12).

NUREG-1855, Revision 1, Guidance on the Treatment of Uncertainties Associated with PRAs [Probabilistic Risk Assessments] in Risk-Informed Decisionmaking, dated March 2017 (Reference 13).

NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, (SRP) Section 16.1, Risk-Informed Decision Making: Technical Specifications, dated March 2007 (Reference 14) and Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance, June 2007 (Reference 15).

Nuclear Energy Institute (NEI) Topical Report (TR) NEI 06-09 Revision 0-A (NEI 06-09-A), Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines, dated October 2012 (Reference 16), provides guidance for risk-informed TSs. The NRC staff issued a final model SE approving NEI 06-09 on May 17, 2007 (Reference 17).

The licensees submittal cites RG 1.200, Revision 2, for the internal events PRA (which includes internal floods) and fire PRA models. Although RG 1.200 has been updated to Revision 3, the NRC staff finds it still acceptable to use Revision 2 to demonstrate the technical acceptability of the Fermi 2 PRA models. This is because the update does not introduce any technical changes that would affect the determination of technical acceptability.

2.2 Description of the RICT Program 10 CFR 50.36(c)(2) requires that TSs contain LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO is not met, the licensee must shut down the reactor or follow any remedial or required action (e.g.,

testing, maintenance, or repair activity) permitted by the TSs until the condition can be met. The remedial actions (ACTIONS) associated with an LCO contain Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s) (CT). The CTs are referred to as the front stops in the context of this SE. For certain conditions, the TSs require exiting the Mode of Applicability of an LCO (e.g., shut down the reactor).

The licensees submittal requested approval to add a RICT Program to the Administrative Controls section of the TSs, and modify selected CTs to permit extending the CTs, provided risk is assessed and managed as described in NEI 06-09-A. Consistent with Table 1 of TSTF-505, Revision 2, for Conditions requiring additional technical justification, the licensee provided several plant-specific LCOs and associated Actions for which Fermi 2 proposed to be included in the RICT Program, along with additional justification. The NRC staffs review of these variations and the justification is provided in Section 3.2.1 of this SE.

The licensee is proposing no changes to the design of the plant or any operating parameter, and no new changes to the design basis in the proposed changes to the TSs. The effect of the proposed changes, when implemented, will allow CTs to vary based on the risk significance of the given plant configuration (i.e., the equipment out of service at any given time), provided that the system(s) retain(s) the capability to perform the applicable safety function(s) without any further failures (e.g., one train of a two-train system is inoperable). These restrictions ensure that consistency with the defense-in-depth (DID) philosophy is maintained by following existing guidance when the capability to perform TS safety function(s) is lost.

The proposed RICT Program uses plant-specific operating experience for component reliability and availability data. Thus, the allowances permitted by the RICT Program are directly reflective of actual component performance in conjunction with component risk significance.

2.2.1 TS 1.0, Use and Application:

The licensee proposes to add Example 1.3-8 to TS 1.3, Completion Times, to read as follows:

EXAMPLE 1.3-8 ACTIONS When a subsystem is declared inoperable, Condition A is entered.

The 7 day Completion Time may be applied as discussed in Example 1.3-2. However, the licensee may elect to apply the Risk Informed Completion Time Program which permits calculation of a Risk Informed Completion Time (RICT) that may be used to complete the Required Action beyond the 7 day Completion Time.

The RICT cannot exceed 30 days. After the 7 day Completion Time has expired, the subsystem must be restored to OPERABLE status within the RICT, or Condition B must also be entered.

The Risk Informed Completion Time Program requires recalculation of the RICT to reflect changing plant conditions. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

If the 7 day Completion Time clock of Condition A has expired and subsequent changes in plant condition result in exiting the applicability of the Risk Informed Completion Time Program without restoring the inoperable subsystem to OPERABLE status, Condition B is also entered, and the Completion Time clocks for Required Actions B.1 and B.2 start.

If the RICT expires or is recalculated to be less than the elapsed time since the Condition was entered and the inoperable subsystem has not been restored to OPERABLE status, Condition B is also entered, and the Completion Time clocks for Required Actions B.1 and B.2 start. If the inoperable subsystems are restored to OPERABLE status after Condition B is entered, Conditions A is exited, and therefore, the Required Actions of Condition B may be terminated.

2.3 Deletion of Second Completion Times Consistent with TSTF-439, the licensee proposed to delete the second CTs from the relevant TSs. The TS Example 1.3-3 Actions table would be revised as follows:

EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One Function X subsystem inoperable.

A.1 Restore Function X subsystem to OPERABLE status.

7 days AND 10 days from discovery of failure to meet the LCO B.

One Function Y subsystem inoperable.

B.1 Restore Function Y subsystem to OPERABLE status.

72 days AND 10 days from discovery of failure to meet the LCO In the accompanying description to TS Example 1.3-3, the last paragraph, which explains the requirements for second completion times, would also be deleted. This paragraph would be replaced with the following:

It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. However, doing so would be inconsistent with the basis of the Completion Times. Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.

In addition, a reference to TS Example 1.3-3 describing second CTs also will be deleted from the description of Section of TS 1.3. Similarly, the second CTs would be deleted in TS 3.8.7, Distribution Systems - Operating, Required Actions A.1 and B.1.

2.4 Description of TSTF-591, Revision 0 The licensees proposed changes consistent with TSTF-591 modify the TS 5.5.16 RICT Program of TSTF-505, Revision 2, to add hazard groups required for a RICT calculation, update the reference for RG 1.200 from Revision 2 to Revision 3, and reference a new reporting requirement. This reporting requirement would be located in TS 5.6.9, Risk Informed Completion Time (RICT) Program Upgrade Report, which would require the licensee to submit a report to the NRC before calculating a RICT using a newly developed method.

2.5 Other Technical Specification Changes In section 2.3 of attachment 1 to the LAR, the licensee proposed an administrative variation that would delete requirements that permitted mechanical draft cooling tower fan pedestal maintenance using a one-time CT extension from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to seven days. The changes were approved on October 30, 2023, in license amendment 226 (Reference 32). This allowance is currently a footnote to the CT for Required Action A.1 of TS 3.7.2, Emergency Equipment Cooling Water (EECW)/Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS), and the CT for Required Action B.4 of TS 3.8.1 AC Sources - Operating.

The one-time change expired on November 19, 2023.

3.0 TECHNICAL EVALUATION

An acceptable approach for making risk-informed decisions about proposed TS changes, including both permanent and temporary changes, is to demonstrate that the proposed licensing basis (LB) changes meet the five key principles provided in Section C of RG 1.174, Revision 3, and the three-tiered approach outlined in Section C of RG 1.177, Revision 2. These key principles and tiers are:

Principle 1:

The proposed LB change meets the current regulations unless it is explicitly related to a requested exemption.

Principle 2:

The proposed LB change is consistent with the defense in depth (DID) philosophy.

Principle 3:

The proposed LB change maintains sufficient safety margins.

Principle 4:

When the proposed LB change results in an increase in risk, the increase should be small and consistent with the intent of the Commissions policy statement on safety goals for the operations of nuclear power plants.

Tier 1: PRA Capability and Insights Tier 2: Avoidance of Risk-Significant Plant Configurations Tier 3: Risk-Informed Configuration Risk Management Principle 5:

The impact of the proposed LB change should be monitored by using performance measures strategies.

For TSTF-439, an acceptable approach to demonstrate that the proposed licensing basis changes are satisfactory consists of demonstrating that the proposed changes adhere to 10 CFR 50.36(c)(2) and (c)(5) and are consistent with elements included in the NRCs Reactor Oversight Process (ROP).

3.1 Method of NRC Staff Review Each of the key principles and tiers described above are addressed in NEI 06-09-A and approved in the final model SE issued by the NRC for TSTF-505, Revision 2. NEI 06-09-A provides a methodology for extending existing CTs, and to thereby delay exiting the operational mode of applicability or taking Required Actions, if risk is assessed and managed within the limits and programmatic requirements established by a RICT Program. The NRC staffs evaluation of the licensees proposed use of RICTs against the key safety principles of RGs 1.174 and 1.177 is discussed below.

For TSTF-439, the guidance in the Traveler provides a method for removing the second completion times from the affected TS Required Actions. The licensees LAR highlighted the controls of the Maintenance Rule, the ROP, and the new requirement in TS Section 1.3. The application also included proposed changes to the TS bases. Bases are not part of the TSs, but the NRC staff confirmed that the licensee described the basis for each revised TS requirement accurately, as set forth in Chapter 16 of NUREG-0800. The NRC staffs evaluation of the licensees proposed removal of the second CTs is provided below.

3.2 Review of Key Principles 3.2.1 Key Principle 1: Evaluation of Compliance with Current Regulations The CTs in the current TSs were established using experiential data, risk insights, and engineering judgement. The RICT Program provides the necessary administrative controls to permit extension of CTs and, thereby, delay reactor shutdown or Required Actions if risk is assessed and managed appropriately within specified limits and programmatic requirements, and the safety margins and DID remain sufficient. The option to determine the extended CT in accordance with the RICT Program allows the licensee to perform an integrated evaluation in accordance with the methodology prescribed in NEI 06-09-A and proposed TS 5.5.16, Risk Informed Completion Time Program. The RICT is limited to a maximum of 30 days (termed the backstop).

The typical CT is modified by the application of the RICT Program as shown in the following example. The changed portion is indicated in italics.

As described in section 2.3 of this SE, the licensees proposed changes adopt TSTF-439, which deletes the second CTs from the affected Required Actions, revises the Improved Standard Technical Specifications Example 1.3-3 to remove the second CTs, and revise the discussion portion of that example to state that alternating between Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO is inconsistent with the basis of the CTs and is inappropriate. Therefore, the licensee shall have administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO is not inappropriately extended. The NRC staff reviewed the proposed changes to the TSs and determined that they meet the standards for TSs as delineated in 10 CFR 50.36(c)(5). Additionally, the changes to the TSs were reviewed for technical clarity and consistency with customary terminology and format in accordance with Chapter 16 of the Standard Review Plan.

In Attachment 1, Description and Assessment of the Proposed Changes; Attachment 5, Cross-Reference of TSTF-505, TSTF-591, TSTF-439, and Fermi Technical Specifications; and, List of Revised Required Actions to Corresponding PRA Function, to the LAR, as supplemented, the licensee provided a list of the TSs, associated LCOs, and Required Actions for the CTs that included modifications and variations from the approved TSTF-505. The modifications and variations consisted of proposed changes to the Required Actions and CTs.

The NRC staff reviewed the proposed changes to the TSs, associated LCOs, Required Actions, and CTs provided by the licensee for the scope of the RICT Program. The NRC staff also reviewed the removal of second CTs consistent with TSTF-439 and evaluated the incorporation of the RICT Program under existing regulations and processes, along with the licensees administrative controls. The NRC staff concluded, with the incorporation of the RICT Program, that the required performance levels of equipment specified in the licensees TS LCOs are not changed and only the required CTs for the Required Actions are modified, such that 10 CFR 50.36(c)(2) will continue to be met. Based on the discussion provided above, the NRC staff finds that the proposed RICT Program provided in Section 2.0 of this SE, LCOs, Required Actions, and CTs meet the first key principle of RGs 1.174 and 1.177.

As discussed in Section 2.5 of this SE, the licensee proposed administrative changes that are not included in TSTF-505, TSTF-439, or TSTF-591. The NRC staff reviewed the proposed TS changes and found that they are non-technical and editorial in nature because they are expired requirements. The changes will simplify the requirements and improve consistency within the TSs. Therefore, staff finds these changes acceptable.

3.2.2 Key Principle 2: Evaluation of Defense in Depth In RG 1.174, Revision 3, the NRC identified the following considerations used for evaluation of how the LB change is maintained for the defense-in-depth (DID) philosophy:

Preserve a reasonable balance among the layers of defense.

Preserve adequate capability of design features without an overreliance on programmatic activities as compensatory measures.

Preserve system redundancy, independence, and diversity commensurate with the expected frequency and consequences of challenges to the system, including consideration of uncertainty.

Preserve adequate defense against potential common cause failures (CCFs).

Maintain multiple fission product barriers.

Preserve sufficient defense against human errors.

Continue to meet the intent of the plants design criteria.

The licensee requested the use of a RICT Program to extend the existing CTs for the respective TS LCOs prescribed in Attachment 2 of the LAR, as supplemented. For the TS LCOs, in and Enclosure 1 of the LAR, as supplemented, the licensee provided a description and assessment of the redundancy and diversity for the proposed changes. The NRC staffs evaluation of the proposed changes for these LCOs assessed Fermis redundant or diverse means to mitigate accidents to ensure consistency with the plant LB requirements using the guidance prescribed in RG 1.174, RG 1.177, and TSTF-505, to ensure adequate DID (for each of the functions) to operate the facility in the proposed manner (i.e., that the changes are consistent with the DID criteria).

, Information Supporting Instrumentation Redundancy and Diversity, and of the LAR as supplemented, provided information supporting the evaluation of the redundancy, diversity, and DID for each Fermi 2s TS LCO and TS Required Action as it related to instrumentation and control (I&C) and electrical power systems. The NRC staff confirmed that for the following TS LCOs, the above DID criteria were applicable except for the criteria for maintaining multiple fission product barriers.

LCOs related to I&C:

3.3.1.1 Reactor Protection System (RPS) Instrumentation 3.3.2.2 Feedwater and Main Turbine High Water Level Trip Instrumentation 3.3.4.1 Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT)

Instrumentation 3.3.5.1 Emergency Core Cooling System (ECCS) Instrumentation 3.3.5.2 Reactor Core Isolation Cooling (RCIC) System Instrumentation 3.3.6.1 Primary Containment Isolation Instrumentation 3.3.7.2 Mechanical Vacuum Pump (MVP) Trip Instrumentation 3.3.7.3 Gland Seal Exhauster (GSE) Trip Instrumentation 3.3.8.1 Loss of Power (LOP) Instrumentation LCOs related to electrical power systems:

3.8.1 AC [alternating current] Sources - Operating 3.8.4 DC [direct current] Sources - Operating 3.8.7 Distribution Systems - Operating For the TS LCOs specific to I&C, the NRC staff reviewed the specific trip logic arrangements, redundancy, backup systems, manual actions, and diverse trips specified for each of the protective safety functions and associated instrumentation as described in the associated Updated Final Safety Analysis Report (UFSAR) (Reference 18) sections, and as reflected in, as supplemented, of the LAR for each I&C LCO above. The NRC staff verified that in accordance with the Fermi 2 UFSAR and equipment and actions credited in Attachment 6, as supplemented, of the LAR, in all applicable operating modes, the affected protective feature would perform its intended function by ensuring the ability to detect and mitigate the associated event or accident when the CT of a channel is extended. Furthermore, the NRC staff concludes that there is sufficient redundancy, diversity, and DID, to protect against CCFs and potential single failure for the Fermi 2 instrumentation systems evaluated in LAR Attachment 2 during a RICT. There is at least one diverse means specified by the licensee for initiating mitigating action for each accident event, thus providing DID against a failure of instrumentation during the RICT for each TS LCO. The DID specified by the licensee does not overly rely on manual actions as the diverse means; therefore, there is not over-reliance of programmatic activities as compensatory measures. The NRC staff finds that the intent of the plants design criteria (e.g., safety functions) for the above TS LCOs related to I&C are maintained.

According to UFSAR Section 8.3.1.1, alternating current (ac) offsite power connects to the 4.16 kilovolt (kV) Class 1E onsite power system through station service transformers. One station service transformer from 345 kV switchyard supplies Division 2 loads, and the other station service transformer from 120 kV switchyard supplies Division 1 loads. The Class 1E onsite power system consists of two ESF buses per division with each bus backed by a dedicated diesel generator that supplies half of the ESF load for that division (one load group). One division is required for safe shutdown. According to UFSAR Section 8.3.2.1.2, the 260/130-V direct current (dc) Class 1E power system consists of two independent divisions. Each 260 Vdc battery is center-tapped and supplies 130 Vdc to each of two Class 1E DC buses per division with each bus supplying a DC load group. Each 130 Vdc portion of the 260 Vdc battery is supplied by its own battery charger. Only two Class 1E 130 Vdc buses per division are required for safe shutdown.

The NRC staff evaluated the LAR for a potential loss of function (LOF) for each electrical proposed RICT based on TSTF-505. The NRC staff did not find any potential LOF for the proposed RICTs. The NRC staff reviewed the LAR and the supplement dated December 19, 2024, to verify that each effected electrical TS LCO condition can be entered voluntarily or involuntarily based on NEI 06-09-A, and to evaluate if the affected electrical power systems under those TS LCO conditions could perform their safety functions (assuming no additional failures other than those considered in the applicable RICT condition). The NRC staff verified the design success criteria in LAR Table E1-1 for each of the electrical TS LCO conditions are adequate and finds that the minimum operable electrical power systems would remain available to support their safety functions to mitigate postulated design basis accidents (DBAs), safely shutdown the reactor, and maintain the reactor in a safe shutdown condition. The NRC staff also finds that RICT estimates provided for each of the electrical TS LCO conditions in the LAR Table E1-2 are consistent with NEI 06-09A. Based on the above evaluation, the NRC staff finds that the Fermi 2 electrical power systems would continue to provide safety functions as intended with the proposed TS changes.

In Enclosure 12, Risk Management Action Examples, of the LAR, the licensee provided examples of risk management actions (RMAs) that may be considered during a RICT Program entry for the above required conditions to reduce the risk impact and ensure adequate defense-in-depth. The NRC staff evaluated the RMA examples provided in Enclosure 12-Risk Management Action Examples, Section 4.0, including the electrical examples for one EDG inoperable; one offsite circuit inoperable; one offsite circuit inoperable AND one or both EDGs in one Division inoperable; and one battery charger inoperable. The NRC staff determined that the RMAs had the required level of detail, that would reduce risk impact and provide adequate defense-in-depth. Based on the review, the NRC staff determined that those examples provide reasonable assurance that the actual RMAs when implemented to monitor and control the risk for each TS LCO condition will be of similar quality and tailored for that LCO.

The NRC staff reviewed the licensees proposed electrical TS LCO condition changes and supporting documentation. Based on the evaluations above, the NRC staff finds that given reduced redundancy in various LCO conditions, the CT extensions, as allowed by the RICT Program, are acceptable because (a) the capacity and capability of the remaining operable electrical systems to perform their safety functions (assuming no additional failures) would remain adequate, and (b) the licensees identification and implementation of RMAs as compensatory measures, in accordance with the RICT Program, would continue to provide adequate defense-in-depth.

The NRC staff notes that while in a TS LCO condition, the redundancy of the function will be temporarily relaxed and, consequently, the system reliability would be degraded accordingly.

The NRC staff examined the design information from the Fermi 2 UFSAR and the risk-informed TS LCO conditions for the affected safety functions. Based on this information, the NRC staff confirmed that under any given design-basis accident evaluated in the Fermi UFSAR, the affected protective features maintain adequate DID.

Considering that the CT extensions will be implemented in accordance with the NEI 06-09-A guidance, which also considers RMAs and the redundancy of the offsite and onsite power system, the NRC staff finds that the plant will maintain adequate DID. Therefore, the NRC staff finds that the TS LCO conditions proposed by the licensee in attachment 5 to the LAR, as supplemented, are acceptable for the RICT Program.

The NRC staff reviewed all the TS LCOs proposed by the licensee in Attachment 5 to the LAR, as supplemented, and concludes that the proposed changes do not alter the ways in which the Fermi 2 systems fail, do not introduce new CCF modes, and the system independence is maintained.

The NRC staff finds that extending the CTs associated with the TS LCO conditions proposed by the licensee in attachment 5 to the LAR, as supplemented, with the RICT Program following loss of redundancy, but maintaining the capability of the system to perform its safety function, is an acceptable reduction in DID during the proposed RICT period provided that the licensee identifies and implements compensatory measures in accordance with the RICT Program during the extended CT.

Based on the above evaluation, the NRC staff finds that the licensees proposed changes are consistent with the NRC-endorsed guidance described in NEI 06-09-A along with TSTF-439, Revision 2. Further, the NRC staff finds that the licensee satisfied the second key principle in RGs 1.177 and 1.174. Finally, the NRC staff concludes that the changes are consistent with the DID philosophy as described in RG 1.174.

3.2.3 Key Principle 3: Evaluation of Safety Margins 10 CFR 50.55a(h) requires, in part, that [p]rotection systems of nuclear power reactors of all types must meet the requirements specified in this paragraph. Section 2.2.2, Technical Specification Change Maintains Sufficient Safety Margin (Principle 3), of RG 1.177 states, in part, that sufficient safety margins are maintained when:

a.

Codes and standards or alternatives approved for use by the NRC are met.

b.

Safety analysis acceptance criteria in the final safety analysis report (FSAR) are met or proposed revisions provide sufficient margin to account for analysis and data uncertainties The licensee is not proposing to change any quality standard, material, or operating specification in this application. In the LAR, the licensee proposed to add a new program, Risk Informed Completion Time Program, in section 5.5, Programs and Manuals, of the Fermi 2 TSs, which requires adherence to NEI 06-09-A.

The NRC staff evaluated the effect on safety margins when the RICT is applied to extend the CT up to a backstop of 30 days in a TS condition with sufficient trains remaining operable to fulfill the TS safety function. Although the licensee will be able to have design-basis equipment out of service longer than the current TSs allow any increase in unavailability is expected to be insignificant and is addressed by the consideration of the single failure criterion in the design-basis analyses. Acceptance criteria for operability of equipment are not changed and, if sufficient trains remain operable to fulfill the TS safety function, the operability of the remaining train(s) ensures that the current safety margins are maintained. The NRC staff finds that if the specified TS safety function remains operable, sufficient safety margins would be maintained during the extended CT of the RICT Program.

Safety margins are also maintained if PRA functionality is determined for the inoperable train, which would result in an increased CT. Credit for PRA functionality, as described in NEI 06-09-A, is limited to the inoperable train, loss-of-offsite power (LOOP), or component.

Based on the above, the NRC staff finds that the design-basis analyses for Fermi 2 remain applicable and unchanged, that sufficient safety margins would be maintained during the extended CT, and that the proposed changes to the TSs do not include any change in the standards applied or the safety analysis acceptance criteria. The NRC staff concludes that the proposed changes meet 10 CFR 50.55a(h) and, therefore, the third key principle of RGs 1.177 and 1.174.

3.2.4 Key Principle 4: Change in Risk Consistent with the Safety Goal Policy Statement Proposed TS section 5.5.16, Risk Informed Completion Time Program, states, in part, that the RICT must be implemented in accordance with NEI 06-09-A, Revision 0, Risk-Managed Technical Specifications (RMTS) Guidelines.

NEI 06-09-A provides a methodology for a licensee to evaluate and manage the risk impact of extensions to TS CTs. Permanent changes to the fixed TS CTs are typically evaluated by using the three-tiered approach described in SRP section 16.1; RG 1.177, Revision 2; and RG 1.174, Revision 3. This approach addresses the calculated change in risk as measured by the change in core damage frequency (CDF) and large early release frequency (LERF), as well as the incremental conditional core damage probability and incremental conditional large early release probability; the use of compensatory measures to reduce risk; and the implementation of a configuration risk management program (CRMP) to identify risk-significant plant configurations.

The NRC staff evaluated the licensees processes and methodologies to determine that the change in risk from implementation of RICTs would be small and consistent with the intent of the Commissions Safety Goal Policy Statement1. In addition, the NRC staff evaluated the licensees proposed changes against the three-tiered approach in RG 1.177, Revision 2, for the licensees evaluation of the risk associated with a proposed TS CT change. The results of the NRC staffs review are discussed below.

3.2.4.1 Tier 1: PRA Capability and Insights Tier 1 evaluates the impact of the proposed changes on plant operational risk. The Tier 1 review involves two aspects: (1) scope and acceptability of the PRA models and their application to the proposed changes, and (2) a review of the PRA results and insights described in the licensees application.

In Enclosure 2, Information Supporting Consistency with Regulatory Guide 1.200, Revision 2, and Enclosure 4, Information Supporting Justification of Excluding Sources of Risk Not Addressed by the PRA Models, to the LAR, the licensee identified the following modeled hazards and alternate methodologies that the licensee proposed to be used in the Fermi 2 RICT Program to assess the risk contribution for extending the CT of a TS LCO:

Internal Events PRA (IEPRA) model (includes internal floods)

Internal Fire Events PRA (FPRA) model Seismic Hazard: a CDF penalty of 3.3 x 10-6 per year and a LERF penalty of either 1.7 x 10-6 per year (inerted containment) or 3.3 x 10-6 per year (de-inerted containment)

Other External Hazards: screened out from RICT Program based on Appendix 6A of the American Society of Mechanical Engineers / American Nuclear Society (ASME/ANS) RA-Sa-2009, Addenda to ASME/ANS RA-S 2008, Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications (ASME/ANS RA-Sa-2009 PRA Standard) (Reference 19) 3.2.4.1.1 PRA Scope The guidance in RG 1.174, Revision 3, states that the scope, level of detail, conformance with the technical elements, and plant representation of the PRA are to be commensurate with its intended use and the role the PRA results play in the integrated decision process.

The NRC staff evaluated the PRA acceptability information provided by the licensee in enclosure 2 to the LAR, including industry peer review results and the licensees self-assessment of the PRA models for internal events, including internal flooding, and fire, against the guidance in RG 1.200, Revision 2. The licensee screened out all external hazard events, except for seismic, as described in section 3.2.4.1.3 of this SE, as insignificant contributors to the RICT calculations. The Fermi 2 PRA model with modifications is used as the CRMP model, as described in section 3.2.4.1.7 of this SE. In addition, the licensee provided a bounding estimate of the seismic CDF and LERF and will include those CDF and LERF values, per section 3.9 of Enclosure 4 to the LAR, in the change-in-risk used to calculate RICTs consistent with the guidance in NEI 06-09-A.

The NRC staff finds that the Fermi scope of modeled PRA hazards, and those hazards for which a modeled PRA is not available where the licensee has proposed use of alternative methods, are appropriate with the RICT application for use in the integrated decision-making process, consistent with RG 1.174, Revision 3.

3.2.4.1.2 Evaluation of PRA Acceptability for Internal Events and Internal Fires Internal Events PRA (Includes Internal Flooding)

In Enclosure 2, section 3 of the March 21, 2024, submittal [1], the licensee explained that the internal events/internal flooding PRA model was subjected to a full-scope peer review in November 2012 against RG 1.200, Revision 2. Due to performing an updated dependency analysis, a focused scope peer review was conducted in February 2014. A second focused scope peer review regarding LERF was conducted in May 2018.

Subsequently, the licensee conducted an Independent Assessment in December 2017 and June 2018 to close the finding-level facts and observations (F&Os) using the Appendix X process documented in the NEI letter to the NRC Final Revision of Appendix X to NEI 05-04/07-12/12-16, 'Close-out of Facts and Observations, dated February 21, 2017 (Reference 20), as accepted, with conditions by NRC in the letter dated May 3, 2017 (Reference 33). All finding-level F&Os were reviewed and closed using this NRC-accepted process. Hence, the LAR does not identify any open finding-level F&Os.

The NRC staff finds that the Fermi 2 IEPRA (that includes internal flooding) was appropriately peer reviewed consistent with RG 1.200, Revision 2, and that all finding-level F&Os have been closed consistent with the Appendix X process guidance, as accepted, with conditions by the NRC staff. Therefore, the NRC staff concludes that the IEPRA (that includes internal flooding) is acceptable for use in the RICT Program.

Internal Fire (FPRA)

In Enclosure 2, Section 4 to the LAR, the licensee confirmed that the Fermi 2 internal FPRA model received a full-scope peer review in November 2020 using the ASME/ANS RA-Sa-2009 PRA Standard, and RG 1.200, Revision 2. Subsequent independent assessment for closure of F&Os using the Appendix X process, as accepted, with conditions by the NRC staff, was performed in November 2020 and January 2024, which resulted in closure of all finding-level F&Os.

In recent years, the industry has submitted multiple fire PRAs for NRC staff review. During this period both the industry and NRC staff determined that updated guidance, methods, and data would be needed for a licensee to develop a more realistic fire model. To ensure that fire PRA models not previously evaluated by the NRC staff are in alignment, the NRCs PRA Licensing Branch B (APLB) staff provided a series of Audit Questions to ascertain the status of the Fermi 2 fire model. The licensees responses to APLB Audit Questions 01, 02, 03, 04, 05, 06, 07, and 08 provided in the LAR supplement dated December 19, 2024, are noted below:

No methods were used in the FPRA that deviated from the guidance of NUREG/CR-6850 (Reference 34, 35, and 36) (APLB Audit Question 01).

The guidance of NUREG-2233 (Reference 37) was utilized in the Fermi 2 analysis regarding transient heat release rate determination (APLB Audit Question 02).

Fermi 2s treatment of sensitive electronics was consistent with FAQ 13-0004 guidance (Reference 38) (APLB Audit Question 03).

Fermi 2 appropriately modeled the one scenario related to obstructed plume modeling (Reference 39) (APLB Audit Question 04).

Confirmed that Fermi 2s FPRA did not treat any motor-controlled centers as well-sealed (APLB Audit Question 05).

Fermi 2 calculated transient fire frequencies based on NUREG/CR-6850 and FAQ 12-0064 guidance (Reference 40). In addition, Fermi confirmed that the FPRA credits administrative controls of transient materials to reduce transient fire frequencies and have no recorded deviations from these controls (APLB Audit Question 06).

Fermi 2s FPRA does not utilize the guidance of FAQ 14-0008 (Reference 41) since Fermi 2 does not have rear panels in the control room (APLB Audit Question 07).

Fermi 2s FPRA incorporates the updated data and guidance related to NUREG-2169, NUREG/CR-7150, NUREG-2230, and NUREG 2178 (References 42, 43, 44, and 45, respectively) (APLB Audit Question 08).

Based on the above responses, the NRC staff finds that the Fermi 2 fire PRA model has incorporated all the updated guidance, methods, and data that are applicable to Fermi 2.

The NRC staff finds that the Fermi FPRA was appropriately peer reviewed consistent with RG 1.200, Revision 2, and that all finding-level F&Os have been closed consistent with the Appendix X process guidance, as accepted, with conditions by the NRC staff. Therefore, the NRC staff concludes that the FPRA is acceptable for use in the RICT Program.

3.2.4.1.3 Evaluation of External Hazards Evaluation of Seismic Hazard The licensees approach for including the seismic risk contribution in the RICT calculation is to add a penalty seismic CDF and a penalty seismic LERF to each RICT calculation. The proposed bounding seismic CDF estimate is based on using the plant-specific seismic hazard curves developed in response to the Near-Term Task Force (NTTF) recommendation 2.1 (Reference 21) and a plant-level high confidence of low probability of failure (HCLPF) capacity of 0.3g referenced to peak ground acceleration (PGA). The uncertainty parameter for seismic capacity was represented by a composite beta factor (c) of 0.4. The NRC staff finds that the method to determine the baseline seismic CDF is acceptable because it is consistent with the approach used in NRC Generic Issue (GI)-199, Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing Plants (Reference 22) and used HCLPF and c values cited for Fermi 2 in Table C-2 of the GI-199 report. The calculated seismic CDF penalty is 3.3 x 10-6 per year. The NRC staff performed an independent convolution using the input parameters identified by the licensee to confirm the proposed seismic CDF penalty.

Concerning the proposed bounding seismic LERF estimate, the licensee explains in the LAR that an estimate of the seismic LERF is obtained by convolving the estimated seismic CDF (as described above) with a limiting fragility for containment integrity, also assumed to be 0.3g PGA HCLPF for inerted containment. When the containment is de-inerted the licensee assumed a seismic conditional large early release probability (SCLERP) of 1.0. The calculated seismic LERF is either 1.7 x 10-6 per year (inerted containment) or 3.3 x 10-6 (de-inerted containment).

The NRC staff finds that the licensees approach to determining the seismic LERF estimate is acceptable because the use of a 0.3g PGA HCLPF as the limiting fragility for containment integrity is supported by the determination that all structures, systems, and components (SSCs) on the Individual Plant Examination of External Events seismic margins assessment (SMA) safe shutdown equipment list meet or exceed the 0.3g PGA SMA review level earthquake.

The licensee addressed the incremental risk associated with a seismic-induced loss of offsite power (LOOP) in its LAR supplement. As provided in the December 19, 2024, LAR supplement in response to APLC Audit Question 02, the seismic LOOP frequency across the entire hazard interval is 4.0 x 10-6 per year. The seismic LOOP frequency across the entire hazard interval is about 0.2 percent of the total internal events 24-hour non-recovered LOOP frequency of 1.6 x 10-3 per year already addressed in the IEPRA. The NRC staff evaluated the licensees analysis and finds that it adequately addresses the impact of a seismic-induced LOOP on risk and that the exclusion of the impact of a seismic-induced LOOP on risk from the non-recovered LOOP frequency has an insignificant impact on the RICT calculations.

The NRC staff finds that, during RICTs for SSCs credited in the design basis to mitigate seismic events, the licensees proposed methodology captures the risk associated with seismic-induced failures of redundant SSCs because such SSCs are assumed to be fully correlated. By assuming full correlation, the seismic risk for those RICTs will not increase if one of the redundant SSCs is unavailable because simultaneous failure of all redundant trains would be assumed in a seismic PRA. During RICTs for SSCs that are not credited in seismic events, the proposed methodology for considering seismic risk contributions is conservative because the seismic-induced failure of such SSCs would not result in a risk increase associated with the plant configuration during the RICT, but the seismic penalty is still included in the calculation.

During RICTs for SSCs that are credited in seismic events, the proposed methodology is acceptable for this application because the plant-level HCLPF value used for the RICT calculations provides a conservative estimate of HCLPF values for all the credited SSCs.

In summary, the NRC staff finds the licensees proposal to use the seismic CDF contributions of 3.3 x 10-6 per year and a seismic LERF contribution of either 1.7 x 10-6 per year (inerted containment) or 3.3 x 10-6 per year (de-inerted containment) to be acceptable for the licensees RICT Program for Fermi 2 because (1) the licensee used the most current site-specific seismic hazard information, (2) the licensee used an acceptably low plant-level HCLPF value of 0.3g PGA and a composite beta factor of 0.4 consistent with the information for Fermi 2 in the GI-199 evaluation, (3) the licensee determined a seismic LERF penalty based on its estimate of seismic CDF combined with using a containment integrity fragility of 0.3g PGA HCLPF, and (4) adding baseline seismic risk to RICT calculations, which assumes the fully correlated failures, is acceptable for this application.

Evaluation of Extreme Winds and Tornado Hazards Section 4 of Enclosure 4 to the LAR discusses the licensees evaluation of extreme wind and tornado missile hazards for this application. The licensee concluded that the extreme winds hazard can generally be screened from consideration for the TSTF-505 application because the frequency of tornadoes having wind speeds that exceed the design basis of 300 miles per hour is less than 1 x 10-7 per year, tropical storms such as hurricanes are not a concern for Fermi 2 given its inland location, and the risk from straight winds is bounded by the risk from tornadoes.

The licensee also evaluated tornado missile impact on this application and determined that this hazard could be screened for this application because the core damage frequency of tornado missiles is less than 1 x 10-6 per year.

The NRC staff reviewed the licensees evaluation provided in Section 4 of Enclosure 4 to the LAR and found it acceptable for this application because the extreme wind and tornado missile risk assessments used by the licensee include appropriate inputs and assumptions for this application and can be screened from consideration based on Criterion PS4 (Bounding mean CDF is less than 1 x 10-6 per year).

Other External Hazards Besides the seismic and extreme winds and tornado hazards discussed above, the licensee confirmed that other external hazards for Fermi 2 have an insignificant contribution to risk and proposed that these hazards be screened out from the RICT Program.

For external floods, the licensees conclusions in Table E4-4, Fermi 2 Other External Hazards Disposition, of Enclosure 4 to the LAR regarding insignificant risk contribution are based on the Flooding Hazard Re-evaluation Report (FHRR) and the NRC staffs assessment of the Fermi 2 FHRR evaluation for external flooding reports for Fermi 2 (References 23 and 24, respectively).

The analysis provided by the licensee demonstrated that the external flood hazard is adequately addressed by the Fermi 2 design-basis flooding conditions.

Regarding the frazil ice external hazard, the licensee confirmed in response to APLC Audit Question 01 that frazil ice is a recognized external hazard. The response also clarified that the frazil ice hazard is addressed in the Fermi 2 IEPRA and provided an updated Table E4-4 in their December 19, 2024, supplement to specifically address this external hazard.

The licensee provided its assessment of other external hazard risk for the RICT Program in LAR. The hazards assessed in the LAR are those identified for consideration in non-mandatory Appendix 6-A of the ASME/ANS RA-Sa-2009 PRA standard, which provides a guide for identifying most of the possible external events for a plant site.

The NRC staff reviewed the information in the LAR, as supplemented, and finds that the contributions from external flooding and other external hazards have an insignificant contribution to configuration risk and can be excluded from the calculation of the proposed RICTs because they either do not challenge the plant or they are bounded by the external hazards analyzed for the plant. Furthermore, the NRC staff also finds that plant procedures exist to ensure that flood protection features will be available during RICTs to manage the external flooding risk in the RICT Program. For all other external hazards, the NRC staff notes that the preliminary screening criteria and progressive screening criteria used and presented in LAR Table E4-5 are the same criteria that were presented in supporting requirements for screening external hazards EXT-B1, EXT-B2, and EXT-C1 of the ASME/ANS RA-Sa-2009 PRA Standard.

3.2.4.1.4 PRA Results and Insights The licensees proposed change implements a process to determine TS RICTs rather than specific changes to individual TS CTs. NEI 06-09-A delineates that periodic assessment be performed of the risk incurred due to operation beyond the front stop CTs resulting from implementation of the RICT Program and comparison to the guidance of RG 1.174, Revision 3, for small increases in risk. In Enclosure 5, Baseline CDF and LERF, to the LAR, the licensee provided the estimated total CDF and LERF to demonstrate that they meet the 1E-4 per year CDF and 1E-5 per year LERF criteria of RG 1.174 consistent with the guidance in NEI 06-09-A, and that these guidelines will be satisfied for implementation of a RICT.

The licensee has incorporated NEI 06-09-A into the new proposed TS 5.5.16. The estimated total CDF and LERF for Fermi 2 meet the RG 1.174, Revision 3 guidelines; therefore, the NRC staff finds that the PRA results and insights to be used by the licensee in the RICT Program will continue to be consistent with NEI 06-09-A.

3.2.4.1.5 Key Assumptions and Uncertainty Analyses The licensee considered PRA modeling uncertainties and their potential impact on the RICT Program and identified, as necessary, the applicable RMAs to limit the impact of these uncertainties. In Enclosure 9 of the March 21, 2024, submittal (Reference 1), the licensee discussed the identification of key assumptions and sources of uncertainty along with providing the dispositions for impact on the risk-informed application of applicable sensitivities. The licensee evaluated the Fermi 2 PRA model to identify the key assumptions and sources of uncertainty for this application consistent with the RG 1.200, Revision 2, definitions, using sensitivity and importance analyses to place bounds on uncertain processes, to identify alternate modeling strategies, and to provide information to users of the PRA.

In response to APLA Audit Question 08 in the December 19, 2024, LAR supplement, the licensee described its process in identifying sources of uncertainty and assessing their impact.

The licensee stated that their process relied on NRC-accepted Electric Power Research Institute (EPRI) guidance document TR-1026511, Practical Guidance on the Use of PRA in Risk-Informed Applications with a Focus on the Treatment of Uncertainty, and TR-1016737, Treatment of Parameter and Model Uncertainty for Probabilistic Risk Assessments, (References 25 and 26, respectively). The NRC staff finds the Fermi 2 approach regarding the treatment of uncertainties to be acceptable since it is consistent with NRC-accepted guidance.

Based on the NRC staffs review of the licensees dispositions provided in Enclosure 9 to the LAR, as supplemented, the NRC staff finds that the licensee performed an adequate assessment to identify the potential sources of uncertainty, and that the identification of the key assumptions and sources of uncertainty was appropriate and consistent with the guidance in NUREG-1855, Revision 1, and associated EPRI TR-1016737 and EPRI TR-1026511.

Therefore, the staff finds the licensee has satisfied the guidance in RG 1.177, Revision 2, and RG 1.174, Revision 3, and that the identification and treatment of assumptions and model uncertainties for risk evaluation of extended CTs is appropriate for this application and is consistent with the guidance in NEI 06-09-A and therefore acceptable.

3.2.4.1.6 PRA Scope and Acceptability Conclusions As stated in Enclosure 2 to the LAR, the licensee has subjected the PRA models to the peer review processes and submitted the results of the peer review. The NRC staff reviewed the peer-review history, which included the results and findings, the licensees resolutions of peer review findings, and the identification and disposition of key assumptions and sources of uncertainty. The NRC staff concludes that: (1) the licensees PRA models are acceptable to support the RICT Program, and (2) the key assumptions for the PRAs have been identified consistent with the guidance in RG 1.200, Revision 2 and NUREG-1855, Revision 1.

Additionally, the NRC staff finds that the licensees approach for considering the impact of seismic events, non-seismic external hazards and other hazards using alternative methods is acceptable.

Based on the above conclusions discussed in sections 3.2.4.1.1 through 3.2.4.1.5 of this SE, the NRC staff finds that the licensee has satisfied the intent of Tier 1 in RG 1.177, Revision 2 and RG 1.174, Revision 3 for determining the PRA acceptability, and that the scope of the modeled PRA hazards, and those hazards for which a modeled PRA is not available where the licensee has proposed use of alternative methods (i.e., IEPRA, FPRA, and the use of a bounding analysis for seismic events) is appropriate for this application.

3.2.4.1.7 Application of PRA Models in the RICT Program The Fermi 2 baseline PRA models that are determined to be acceptable in Section 3.2.4.1.6 of this SE will be modified as an application-specific PRA model (i.e., CRMP tool), that will be used to analyze the risk for an extended CT. The CRMP model produces results (i.e., risk metrics) that are consistent with the NEI 06-09-A guidance. Throughout the entirety of the LAR and associated supplements as discussed below, and specifically Table E1-1, the licensee provided all information to support the requested LCO actions proposed for the Fermi 2 RICT Program consistent with all the Limitations and Conditions prescribed in Section 4.0 of NEI 06-09-A.

LAR Enclosure 8, Section 2, identifies several specific modifications that are made to the baseline PRA models to produce the CRMP model, or the real time risk (RTR) tool, that is used to make the RICT calculations. In response to APLA Audit Question 04 in the December 19, 2024, LAR supplement, the licensee provided additional details on how adjustments to the CRMP model are made to reflect changing conditions that could affect the model and associated RICT calculations, such as seasonal variations that could impact success criteria.

The licensee stated it will set the season alignment to their most conservative assumptions prior to RICT implementation (identified as an implementation item in the revised attachment 7 provided in the supplement). The NRC staff finds that the licensees CRMP model is in accordance with NEI 06-09-A with respect to the treatment of changing plant conditions, such as the weather and seasonal variations, because it assesses these conditions conservatively for the RICT calculations.

LAR Enclosure 1, Table E1-1 identifies each TS LCO proposed for the RICT Program, describes whether the systems and components involved in the TS LCO are implicitly or explicitly modeled in the PRA, and compares the design basis and PRA success criteria. For certain TS LCO conditions, the table explains that the associated SSCs are not modelled in the PRAs but will be represented using a surrogate event that fails the function performed by the SSC.

In response to APLA Audit Question 06a in the December 19, 2024, LAR supplement, the licensee provided additional clarification for TS LCO 3.3.1.1, reactor protection system instrumentation, Conditions A and B functions. The licensee clarified that the PRA model surrogate is to fail a full division (Division A and C or Division B and D) of automatic rod insertion. The NRC staff finds that the full division surrogate bounds the functions related to TS LCO 3.3.1.1.A and B and is consistent with the guidance of NEI 06-09-A.

In response to APLA Audit Question 06b in the December 19, 2024, LAR supplement, the licensee provided additional clarification for TS LCO 3.3.5.1, initiation of the Core Spray, and High-and Low-Pressure Core Injection Systems, as well as instruments for tripping High Pressure Core Injection on high Reactor Vessel level, Conditions B and C. The licensee clarified that the PRA model surrogate is the impacted component start/stop relay or pump start basic events set to failed for one full division. The NRC staff finds that the component start/stop relay surrogate bounds the function of the actuation instruments related to TS LCO 3.3.5.1.B and C and is consistent with the guidance of NEI 06-09-A.

In response to APLA Audit Question 06c in the December 19, 2024, LAR supplement, the licensee provided additional clarification for TS LCO 3.3.5.1,high suppression pool level HPCI pump trip, Condition D. The licensee clarified that the PRA model surrogate is to fail the automatic switchover to this long-term source that effectively fails the HPCI pump. The NRC staff finds that this surrogate bounds the function related to TS LCO 3.3.5.1.D and is consistent with the guidance of NEI 06-09-A.

In response to APLA Audit Question 06d in the December 19, 2024, LAR supplement, the licensee provided additional clarification for TS LCO 3.3.5.1, automatic depression system (ADS) initiation, Conditions E and F. The licensee clarified that the PRA model surrogate for the inoperability of the ADS initiation logic is to fail all the ADS valves from opening. The NRC staff finds that the ADS valves failure surrogate bounds the function of the ADS initiation logic and is consistent with the guidance of NEI 06-09-A.

In response to APLA Audit Question 06e in the December 19, 2024, LAR supplement, the licensee provided additional clarification for TS LCO 3.6.1.3, primary containment isolation valves, Condition A. The licensee clarified that the PRA model surrogate for the inoperability of a primary isolation valves is the modeled large pre-existing containment failure that leads to containment bypass. The NRC staff finds that the large pre-existing containment failure surrogate bounds the function of the primary containment isolation valves and is consistent with the guidance of NEI 06-09-A.

In response to APLA Audit Question 06f in the December 19, 2024, LAR supplement, the licensee provided additional clarification for TS LCO 3.7.2, ultimate heat sink reservoir, Condition A. The licensee clarified that the PRA model surrogate for the inoperability of each reservoir is to fail the modeled associated systems pumps connected to the reservoir. The NRC staff finds that the failure of the associated system pump surrogate bounds the function of the ultimate heat sink reservoir and is consistent with the guidance of NEI 06-09-A.

In response to APLA Audit Question 06g in the December 19, 2024, LAR supplement, the licensee provided additional clarification for TS LCO 3.7.6, main turbine bypass system and moisture separator reheater, Condition A. The licensee clarified that the PRA model surrogate for the inoperability of the turbine bypass and reheater is to fail the modeled steam jet air ejector. The NRC staff finds that the failure of steam jet air ejector surrogate bounds the function of the main turbine bypass system and moisture separator reheater and is consistent with the guidance of NEI 06-09-A.

Regarding the LCOs for TS 3.3.6.1, primary containment isolation instrumentation, Condition A, TS 3.3.7.2, mechanical vacuum pump instrumentation, Condition A, and TS 3.3.7.3, gland seal exhauster trip instrumentation, Condition A, the licensee provided in Attachment 7 of the December 19, 2024, supplement implementation items to adequately model these systems in the PRA used to calculate RICTs.

For emergent conditions in which the extent of condition evaluation for inoperable SSCs is not complete prior to exceeding the CT, the requirement in TSTF-505, Revision 2, is to either (a) numerically account for the increased probability of CCF, or (b) to implement RMAs not already credited in the RICT calculation that support redundant or diverse SSCs that perform the functions of the inoperable SSCs and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs. The NRC staff finds that numerically accounting for an increased probability of CCF, in accordance with RG 1.177, Revision 2, will shorten the estimated RICT based on the particular SSCs involved thereby limiting the time when a CCF could affect risk. Alternatively, implementing actions that can increase the availability of other mitigating SSCs or decrease the frequency of demand on the affected SSCs will decrease the likelihood that a CCF could affect risk. The NRC staff finds that both methods minimize the impact of CCF because they either limit the exposure time, help ensure the availability of alternate SSCs, or decrease the probability of plant conditions requiring the safety function to be performed.

For planned conditions, the licensee states in LAR Enclosure 8, Section 2, that adjustments to CCF grouping and associated probabilities (Fermi 2 uses alpha factors to calculate CCFs) are not necessary when a component is taken out of service for preventive maintenance because (1) [t]he component is not out-of-service for reasons subject to a potential CCF, and (2) the net failure probability for the in-service components includes the CCF contribution of the out-of-service component. The licensee also states, in part, that the CCF events that are related to the out-of-service component are retained and that this is conservative.

Section 3.3.6, Common Cause Failure Consideration, of NEI 06-09-A states, in part, that for all RICT assessments of planned configurations, the treatment of CCFs in the quantitative configuration risk management tools may be performed by considering only the removal of the planned equipment and not adjusting CCF terms. However, RG 1.177 states that when a component is rendered inoperable in order to perform preventative maintenance, the CCF contributions in the remaining operable components should be modified to remove the inoperable component and to only include CCF of the remaining components. The NRC staff finds that the CCF contribution from the out-of-service component is conservatively retained in the following ways: (1) the independent failure rate used in the PRA models includes both independent and dependent failure events (i.e., the dependent failures should be subtracted from the total population of failures to calculate the independent failure rate), and (2) the CCF event probabilities that include the out-of-service component are retained. The NRC staff also finds, however, that this simplification produces both conservative and non-conservative effects.

The CCF probability estimates are uncertain and retaining precision in the calculation of these estimates using a more refined approach will not necessarily improve the accuracy of the results. Therefore, the NRC staff finds that the licensees method is acceptable because, consistent with NEI 06-09-A, the calculations reasonably include CCFs after removing one train for maintenance consistent with the accuracy of the estimates.

The NRC staff did not identify any insufficiencies in the information or the CRMP tool (RTR model) as described in the LAR, as supplemented. However, during the demonstration during the audit, it was determined that Fermi 2 had not yet authorized a procedure for evaluating and changing CCF values. The licensee provided in Attachment 7 of the December 19, 2024, supplement an implementation item to issue an RICT CCF adjustment procedure. Furthermore, as stated in Attachment 1 to the LAR, regarding the Fermi 2 design criteria, the licensee stated that [t]he proposed change does not change the design, configuration, or method of operation of the plant. The NRC staff finds that the Fermi 2 PRA models and CRMP tool used will continue to reflect the as-built, as-operated plant consistent with RG 1.200, Revision 3, for ensuring PRA acceptability is maintained. Therefore, the NRC staff finds that the proposed application of the Fermi 2 RICT Program is appropriate for use in the adoption of TSTF-505 for performing RICT calculations.

3.2.4.2 Tier 2: Avoidance of Risk-Significant Plant Configurations As described in RG 1.177, Revision 2, the second tier evaluates the capability of the licensee to recognize and avoid risk-significant plant configurations that could result if equipment, in addition to that associated with the proposed change, is taken out of service simultaneously or if other risk-significant operational factors, such as concurrent system or equipment testing, are also involved. The limits established for entry into a RICT and for RMA implementation are consistent with the NEI guidance of Nuclear Management and Resources Council (NUMARC) 93-01, Revision 4F (Reference 27), endorsed by RG 1.160, Revision 4 (Reference 28), as applicable to plant maintenance activities. In response to APLA Audit Question 05 in the December 19, 2024, LAR supplement, the licensee confirmed that the Fermi 2 Maintenance Rule monitoring program incorporates the guidance of NUMARC 93-01, as endorsed by RG 1.160.

Based on the licensees incorporation of NEI 06-09-A in the TSs as discussed in LAR, the use of RMAs as discussed in the licensees LAR Enclosure 12, and because the proposed changes are consistent with the Tier 2 guidance of RG 1.177, Revision 2, the NRC staff finds the licensees RICT Program requirements and criteria are consistent with the principle of Tier 2 to avoid risk-significant configurations and, therefore, that the licensees Tier 2 program is acceptable and it adequately supports the proposed implementation of the RICT Program.

3.2.4.3 Tier 3: Risk-Informed Configuration Risk Management Tier 3 of RG 1.177, Revision 2, provides that a licensee should develop a program that ensures the risk impact of out-of-service equipment is appropriately evaluated prior to performing any maintenance activity.

The licensees proposed RICT Program establishes a CRMP, or RTR model, based on the underlying PRA models. In Enclosure 8 to the LAR, the licensee explains the adjustments to PRA models (e.g., adjustments to maintenance unavailability) to ensure the proper use of models in the RTR model calculations. The RTR model is then used to evaluate configuration-specific risk for planned activities associated with the RMTS extended CT and emergent conditions that may arise during an extended CT. This required assessment of configuration risk, along with the implementation of compensatory measures and RMAs, is consistent with the principle of Tier 3 for assessing and managing the risk impact of out-of-service equipment.

In Enclosure 8 to the LAR, the licensee confirmed that future changes made to the baseline PRA models and changes made to the online model (i.e., RTR) are controlled and documented by plant procedures. In Enclosure 10, Program Implementation, to the LAR, the licensee identified the attributes that the RICT Program procedures will address, which are consistent with NEI 06-09-A. The NRC staff finds that the licensee has identified appropriate administrative controls consistent with NEI 06-09-A and 10 CFR 50.36(c)(5).

The NRC staff reviewed the description of the training program provided in the LAR and concluded that the program is consistent with the training requirements set forth in NEI 06-09-A.

Therefore, the NRC staff finds that the licensee has proposed acceptable administrative controls for the PRA and personnel implementing the RICT Program and will establish appropriate programmatic and procedural controls for its RICT Program, consistent with the guidance of NEI 06-09-A, section 3.2.1, RMTS Process Control and Responsibilities.

Based on the licensees incorporation of NEI 06-09-A in the TSs, as discussed in its LAR, the use of RMAs, as discussed in LAR Enclosure 12, and because the proposed changes are consistent with the Tier 3 guidance of RG 1.177, Revision 2, the NRC staff finds that the licensees Tier 3 program is acceptable and it adequately supports the proposed implementation of the RICT Program.

3.2.4.4 Key Principle 4 Conclusions Based on the above, the licensee has demonstrated the technical acceptability and scope of its PRA models and alternative methods. This includes considering the impact of seismic events, non-seismic external hazards such as extreme winds and tornadoes, and other hazards, and that the models can support implementation of the RICT Program for determining extensions to CTs. The licensee has made proper consideration of key assumptions and sources of uncertainty. The risk metrics are consistent with the approved methodology of NEI 06-09-A and the acceptance guidance in RG 1.177 and RG 1.174. The RICT Program will be controlled administratively through plant procedures and training and follows the NRC-approved methodology in NEI 06-09-A. The NRC staff concludes that the RICT Program satisfies the fourth key principle of RG 1.177 and is, therefore, acceptable.

3.2.5 Key Principle 5: Performance Measurement Strategies - Implementation and Monitoring For TSTF 439, Revision 2, there are two existing programs that provide a strong disincentive to licensees continuing operation with alternating Required Actions. These programs are the monitoring report program required under the Maintenance Rule (10 CFR 50.65) and the ROP.

TSTF-439 deletes the second CTs; those CTs had been based upon an NRC concern that a plant could continue to operate indefinitely without meeting an LCO by alternating compliance between two or more separate TS Conditions. TSTF-439 explains that paragraph 50.65(a)(4) of 10 CFR is a better mechanism to assure that the LCO is met than the imposition of a second CT, because the monitoring report considers all inoperable risk-significant equipment, not just the one or two systems governed by the same LCO. Furthermore, as discussed above, the monitoring report requires each licensee to monitor the performance or condition of SSCs against licensee established goals to ensure the SSCs are capable of fulfilling their intended functions. The performance and condition monitoring activities required by 10 CFR 50.65 identify maintenance practices that would result from multiple entries into the actions of the TSs and unacceptable unavailability of these SSCs. The effectiveness of these performance monitoring activities, and associated corrective actions is evaluated at least every refueling cycle, not to exceed 24 months per 10 CFR 50.65.

In addition to the monitoring report, the reporting of performance indicator data governed by NEI 99-02, Regulatory Assessment Performance Indicator Guideline (Reference 46), as endorsed by RIS 2001-11, Voluntary Submission of Performance Indicator Data (Reference 47),

establishes an acceptable method for the submission of performance indicator data to the NRC.

The ROP consists of cornerstones that include inspection of the indicators to ensure all ROP objectives are being met. The mitigating systems cornerstone specifically addresses emergency AC power systems, which encompasses the AC sources and distribution system LCOs. Any extended unavailability of the emergency AC power systems due to multiple entries into the TS Required Actions would affect the NRC staffs evaluation of the licensees performance indicator data provided under the ROP. The licensees performance within the mitigating systems ROP cornerstone provides reasonable assurance that the inappropriate use of TS CTs will be monitored.

In addition to these regulatory programs, the administrative controls discussed above in Sections 2.4 and 3.2.1 of this safety evaluation limit the maximum time allowed for any combination of Conditions that result in a single contiguous failure to meet the LCO. The NRC staff concludes that the licensee continues to have mechanisms in place to monitor and to limit the maximum time allowed for any combination of conditions that could result in a single contiguous failure to meet the LCO. The NRC staff finds the proposed deletion of second CTs are acceptable because multiple, continuous entries into TS Conditions, without meeting the LCO, will be adequately controlled by: (1) the licensees administrative controls, (2) the CRMPs as implemented to meet the requirements of the monitoring report to assess and manage risk and performance indicators, (3) assessment of the licensees performance within the mitigating systems ROP cornerstone, and (4) the requirements described in TS 1.3, Completion Times.

In addition, the NRC staff finds the monitoring report provides adequate assurance against the inappropriate use of combinations of TS Conditions that result in a single contiguous occurrence of failing to meet the LCO. Accordingly, consistent with TSTF-439, Revision 2, the NRC staff finds the proposed changes to be acceptable.

For TSTF-505, Revision 2, the need for an implementation and monitoring program is established in RG 1.177, Revision 2, and RG 1.174, Revision 3, to ensure that extensions to TS CTs do not degrade operational safety over time and that no adverse degradation occurs due to unanticipated degradation or common cause mechanisms. An implementation and monitoring program is intended to ensure that the impact of the proposed TS change continues to reflect the availability of SSCs impacted by the change. Revision 3 of RG 1.174 states, in part, monitoring performed in conformance with the Maintenance Rule, 10 CFR 50.65, can be used when the monitoring performed is sufficient for the SSCs affected by the risk-informed application. Enclosure 11 of the March 21, 2024, submittal (Reference 1) states, the SSCs in the scope of the RICT Program are also in the scope of 10 CFR 50.65 for the Maintenance Rule. The Maintenance Rule monitoring programs will provide for evaluation and disposition of unavailability impacts which may be incurred from implementation of the RICT Program.

NEI 06-09-A specifies that the cumulative risk associated with the use of RMTS beyond the front-stop for equipment out of service is to be monitored. In Enclosure 11 to the LAR, the licensee states that the cumulative risk is calculated at least every refueling cycle, not to exceed 24 months. The NRC staff finds that this periodicity is consistent with NEI 06-09-A.

In response to APLA Audit Question 07 provided in the December 19, 2024, supplement, the licensee provided the criteria that would result in an unscheduled PRA model update. The criteria were related to an overall change in risk (CDF or LERF), exceedance of overall CDF or LERF risk value, and significant changes of SSC risk metrics. The NRC staff determined that the Fermi 2 criteria are consistent with previously approved criteria and is acceptable for this application.

The NRC staff concludes that the licensees proposed RICT Program satisfies the fifth key principle of RG 1.177 and RG 1.174 because: (1) as described in Enclosure 11 to the LAR, the RICT Program will monitor the average annual cumulative risk increase as described in NEI 06-09-A, and use this average annual increase to ensure that the program, as implemented, meets RG 1.174 guidance for small risk increases: and (2) all affected SSCs are within the Maintenance Rule program, which is used to monitor changes to the reliability and availability of these SSCs.

3.3 Adoption of TSTF-591, Revision 0 The NRC staff compared the licensees proposed TS changes in Section 2.4 of this SE against the changes approved in TSTF-591. The NRC staff finds that the licensees proposed changes to the Fermi 2 TSs described in Section 2.4 of this SE are consistent with those found acceptable in TSTF-591.

In the SE approving Traveler TSTF-591, the NRC staff concluded that the TSTF-591 proposed changes to STS 5.5.17 (this corresponds to Fermi 2 TS 5.5.16), Risk Informed Completion Time Program, and the proposed addition of STS 5.6.6 (this corresponds to Fermi 2 TS 5.6.9),

Risk Informed Completion Time (RICT) Program Upgrade Report, were acceptable. These modifications were acceptable because, as discussed in that SE, they continued to ensure the PRA models used to calculate a RICT are maintained and upgraded by the licensees appropriate use of endorsed guidance (i.e., the ASME/ANS PRA Standard requirements, and specific industry guidance that the NRC staff has determined are sufficient for determining the acceptability of PRA models and newly developed methods for use in the RICT Program).

Furthermore, as discussed in the Traveler SE, the addition of reporting requirements does not preclude any NRC staff oversight of PRA changes performed to ensure the PRA model(s) continue to be maintained and upgraded consistent with RG 1.200, Revision 3. Therefore, the NRC staff found that the proposed changes to the RICT Program and addition of the RICT Program Upgrade Report requirements were acceptable because they continued to meet the requirements of 10 CFR 50.36(c)(5) by providing administrative controls necessary to assure operation of the facility in a safe manner. For these same reasons, the NRC staff concludes that the corresponding proposed changes to the Fermi 2 TSs in Section 2.4 of this SE will meet the requirements of 10 CFR 50.36(c)(5).

3.4 Technical Conclusion The NRC staff has evaluated the proposed changes against each of the five key principles in RG 1.177, Revision 2 and RG 1.174, Revision 3, and evaluated the optional variations from the NRC-approved TSTF-505, TSTF-439, and TSTF-591 discussed in section 3.2.1 of this SE. The NRC staff concludes that the changes proposed by the licensee satisfy the key principles of risk-informed decision-making identified in RG 1.174, and RG 1.177 and, therefore, the requested adoption of the proposed changes to the TSs and associated guidance is acceptable to assure the regulatory requirements of 10 CFR Part 50 identified in Section 2.1 of this SE will continue to be met.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendment on February 25, 2025. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes the requirements with respect to installation or use of a facilitys components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involve no significant hazards consideration, and there has been no public comment on such finding (89 FR 41999). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors:

Alexander Schwab, NRR Daniel Ju, NRR Keith Tetter, NRR Edmund Kleeh, NRR Ming Li, NRR Khadijah West, NRR Date of Issuance: May 2, 2025 REFERENCES 1

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2 Domingos, C.P., DTE Electric Company letter to U.S. NRC Document Control Desk, Supplement to License Amendmnt Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet a LCO, and TSTF-591, Revision 0, Revise the Risk Informed Completion Time (RICT) Program; dated December 19, 2024 (ADAMS Accession No. ML24354A255).

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6 NRC, FERMI 2 - Audit Summary Report for Application to Adopt TSTF-439, TSTF-505, and TSTF-591, dated February 3, 2025 (ADAMS Accesion No. ML25027A458).

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9 Domingos, C.P., DTE Electric Company letter to U.S. NRC Document Control Desk, Supplement to License Amendmnt Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet a LCO, and TSTF-591, Revision 0, Revise the Risk Informed Completion Time (RICT) Program; dated February 4, 2025 (ADAMS Accession No. ML25035A110).

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11 TSTF, TSTF-439, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO," TSTF-439, Revision 2, dated July 20, 2005 (ML051860296).

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16 Bradley, B., NEI, letter to S. D. Stuchell, NRC, NEI 06-09, Risk Informed Technical Specifications Initiative 4b; Risk Managed Technical Specifications (RMTS) Guidelines, Revision 0-A, dated October 2012 (Package ML122860402).

17 Golder, J. M., NRC, letter to B. Bradley, NEI, Final Safety Evaluation for Nuclear Energy Institute (NEI) Topical Report (TR) NEI 06-09, Risk-Informed Technical Specification Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines (TAC No.

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20 Anderson, V. K., NEI, letter to S. Rosenberg, NRC, Final Revision of Appendix X to NEI 05-04/07-12/12-16, Close-Out of Facts and Observations, NEI 05-04/07-12/12-16, dated February 21, 2017 (Package ML17086A431).

21 DTE Letter to NRC, "DTE Electric Companys Seismic Hazard and Screening Report,

"'Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident'," dated March 31, 2014 (ML14090A326).

22 Hiland, P., NRC, memorandum to B. W. Sheron, NRC, Results of Safety/Risk Assessment of Generic Issue 199, Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing Plants, dated September 2, 2010 (Package ML100270582).

23 DTE Energy Company Letter to NRC, "DTE Electric Submittal of Flooding Hazard Reevaluation Report in Response to March 12, 2012 Information Request Regarding Flood Protection Evaluations," dated March 8, 2013, (ADAMS Accession No. ML13070A199).

24 NRC letter to DTE Electric Company, "Fermi 2 - Staff Assessment of Response to 10CFR 50.54(f) Information Request - Flood-Causing Mechanism Reevaluation (TAC NO.

MF1101)," dated December 30, 2014 (ADAMS Accession No. ML14351A438).

25 EPRI, Treatment of Parameter and Model Uncertainty for Probabilistic Risk Assessments, EPRI TR-1016737, December 2008.

26 EPRI, Practical Guidance on the Use of Probabilistic Risk Assessment in the Risk-informed Treatment of Uncertainty, EPRI TR-1026511, December 2012.

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29 Boyce, T. H., NRC, letter to TSTF, Approval of TSTF-439, "Eliminate Second Completion Times from Discovery of Failure to Meet an LCO, dated January 11, 2006 (ML060120272).

30 TSTF, Technical Specifications Task Force - Transmittal of TSTF-591, Revision 0, "Revise Risk Informed Completion Time (RICT) Program", TSTF-591, Revision 0, dated March 22, 2022 (ML22081A224).

31 NRC, Final SE of TSTF-591, Revision 0, "Revise Risk-Informed Completion Time (RICT)

Program", dated September 21, 2023 (ML23262B230).

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33 U.S. Nuclear Regulatory Commission, letter to Greg Krueger, Nuclear Energy Institute, "U.S.

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Overview," NUREG/CR-6850, Volume 1, dated September 2005 (ML052580075).

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36 37 "Fire Probabilistic Risk Assessment Methods Enhancements," NUREG/CR-6850, Supplement 1, dated September 2010 (ML103090242).

Methodology for Modeling Transient Fires in Nuclear Power Plant Fire Probabilistic Risk Assessment, NUREG-2233, dated May 2020 (ML20091L604) (non-public).

38 Clarifications on Treatment of Sensitive Electronics, FAQ 13-0004, dated December 2013 (ML13322A085).

39 40 "Refining and Characterizing Heat Release Rates from Electrical Enclosures During Fire (RACHELLE-FIRE), Volume 1: Peak Heat Release Rates and Effects of Obstructed Plume,"

NUREG-2178, dated April 2016 (ML16110A140).

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41 Main Control Board Treatment, FAQ 14-0008, dated July 2014 (ML14190B307).

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44 Methodology for Modeling Fire Growth and Suppression Response for Electrical Cabinets Fires in Nuclear Power Plants, NUREG-2230, dated June 2020 (ML20157A148).

45 "Refining and Characterizing Heat Release Rates from Electrical Enclosures During Fire (RACHELLE-FIRE), Volume 2: Fire Modeling Guidance for Electrical Cabinets, Electric Motors, Indoor Dry Transformers, and the Main Control Board" NUREG-2178, Volume 2, dated June 2020 (ML20168A655).

46 NEI, NEI 99-02, Revision 7, "Regulatory Assessment Performance Indicator Guideline.", NEI 99-02, Revision 7, dated August 31, 2013 (ML13261A116).

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48 Baker, S. P., DTE Electric Company letter to U.S. NRC Document Control Desk, Supplement to License Amendmnt Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times

- RITSTF Initiative 4b, TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet a LCO, and TSTF-591, Revision 0, Revise the Risk Informed Completion Time (RICT) Program; dated March 19, 2025 (ADAMS Accession No. ML25078A292).

ML25086A180 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/STSB/BC NRR/DSS/SCPB/BC NAME SArora SRohrer SMehta MValentin DATE 3/27/25 3/31/25 4/8/25 4/4/25 OFFICE NRR/DSS/SNSB/BC NRR/DRA/APLA/BC NRR/DRA/APLB/BC NRR/DRA/APLC/BC NAME DMurdock (A)

RPascarelli EDavidson ANeuhausen DATE 4/7/25 2/8/25 4/7/25 4/4/25 OFFICE NRR/DEX/EEEB/BC NRR/DEX/EICB/BC OGC NLO NRR/DORL/LPL3/BC NAME WMorton FSacko MChwedczuk IBerrios DATE 4/8/25 4/7/25 4/28/25 5/2/2025 OFFICE NRR/DORL/LPL3/PM NAME SArora DATE 5/2/2025

v t e Letter Sequence Other
EPID:L-2024-LLA-0034, TSTF-591 (Approved, Closed)
Initiation Request Acceptance Supplement, Supplement, Supplement Administration Questions Answers Results Approval, Approval Other: ML25027A458, ML25086A180
MONTHYEAR2024-07-30 [Table View]

ML25086A180

Text

SUBJECT:

Dear Peter Dietrich:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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